Opinions — Thursday, July 23, 2026

In Dong Yongqiang v. Fox Factory, Inc., the parties stipulated to dismissal of an appeal from a Trademark Trial and Appeal Board decision in Opposition No. 92081730, which the Federal Circuit granted under Federal Rule of Appellate Procedure 42(b). The court ordered that each side shall bear their own costs.

In Cartessa Aesthetics, LLC v. International Trade Commission, the Federal Circuit granted Cartessa's motion to consolidate Appeals Nos. 2026-1582 and 2026-1881, dismissed both appeals as moot following expiration of the asserted patent, and vacated the ITC's final determination of a Section 337 violation, rejecting intervenor Hydrafacial's argument that potential collateral consequences in ongoing PTO proceedings precluded mootness. The court ordered each side to bear its own costs and remanded with instructions to dismiss the underlying investigation as moot.

The Federal Circuit affirmed the district court's order requiring Moarbes, LLP to pay fifty percent of a $46,438.60 sanctions award imposed for repeated failures to comply with court orders in patent litigation between FrenchPorte IP LLC and C.H.I. Overhead Doors, Inc. Moarbes did not challenge the propriety or amount of the underlying sanctions, but contended it should bear no responsibility for them. Moarbes argued the district court improperly relied on an ex parte letter from FrenchPorte's CEO in allocating responsibility for the sanctions between counsel and client.

The court reviewed whether the district court had actually relied on the disputed ex parte letter, noting that Moarbes conceded its appeal failed absent such reliance. The district court had expressly stated it did not consider the CEO's letter and instead based its allocation on Moarbes's own filings, which established that Moarbes had received at least some funding to comply with court orders yet repeatedly failed to do so. Applying abuse of discretion review, the panel found no error in the district court's even apportionment of sanctions responsibility between law firm and client based on the record before it.

The Federal Circuit reversed in part and affirmed in part the district court's grant of summary judgment of ineligibility under Section 101, addressing patent claims related to digital picture frames that obtain and display images remotely. Ceiva Opco sued Amazon for infringement of four related patents claiming systems for distributing image data to digital picture frames via a network, where users could remotely upload images and adjust settings through a web-based interface rather than requiring physical access to the device.

The court distinguished between claim 19 of the '573 patent (the "digital picture frame" claim) and the remaining "digital display device" claims, finding claim 19 patent-eligible at Alice step one. The court held that claim 19 recited a technological solution to the prior art proximity problem—where users had to physically interact with frames to upload images via memory stick or adjust settings—by requiring a "physically separable" user interface that enables remote access. Applying precedents like Ollnova and Contour IP, the court rejected the district court's characterization of the claims at too high a level of abstraction, finding that the combination of limitations sufficiently captured a concrete technological advancement in digital picture frame technology by specifying how the functional result of remote access is achieved through particular structural requirements.