3 opinions in the patent, trademark, design patent, and trade dress categories. Rule 36 affirmances and non-IP dispositions excluded.
In Integrated DNA Technologies, Inc. v. Tecan Genomics, Inc., Nos. 2026-1904, 26-1905, the Federal Circuit dismissed the appeal from a Patent Trial and Appeal Board decision in IPR2025-00016 pursuant to Federal Rule of Appellate Procedure 42(b) based on the parties' agreement, with each side to bear its own costs.
Panel: Chen, Stoll, Stark
In re Amazon.com Services LLC involves Amazon's petition for a writ of mandamus seeking to compel the U.S. District Court for the Eastern District of Texas to stay patent infringement proceedings filed by Headwater Research LLC pending resolution of a related suit against Google in the Northern District of California. The Federal Circuit denied the petition, holding that Amazon failed to demonstrate a clear and indisputable right to relief under the customer-suit exception to the first-to-file rule, where the case involved two asserted patents (only one overlapping with the Google litigation), multiple infringement theories including Amazon's proprietary ADM system, and Amazon raised its alternative request for severance and partial stay only in a footnote.
Panel: Lourie, Hughes, Stoll
MPH Technologies Oy v. Apple Inc. involves the Federal Circuit's reversal and remand of claim construction rulings regarding two patent families. The court rejected the district court's construction of "secure" terms in the '949 patent family as limited to the IPSec protocol, and reversed the district court's indefiniteness determination for claim 1 of the '581 patent. Following the district court's constructions, the parties had stipulated to noninfringement of the '949 family and invalidity of the '581 patent.
The court's de novo claim construction analysis turned on reconciling competing signals in the specification. Although the specification repeatedly emphasized IPSec (appearing nearly 200 times) and stated that "[a]n essential idea of the invention is to use the standard protocol (IPSec)," the court found this language overcome by express disclaimers that "[t]he invention is not restricted to the details of the figures and accompanying text, or any existing protocols, such as the currently standardised IPSec" and statements that IPSec was merely "preferred." The court distinguished GPNE Corp. v. Apple Inc., where the specification "repeatedly and exclusively" used narrow terms, finding that here the inventor's express language foreclosed reading IPSec as a requirement into the broad claim term "secure" despite the protocol's prominence throughout the specification.