Opinions — Monday, October 5, 2026

The Federal Circuit reversed-in-part, affirmed-in-part, and vacated-in-part the district court's grant of summary judgment of non-infringement in favor of O'Reilly Winship LLC (OWL) on claims of SnapRays LLC's (SnapPower) patents directed to powered electrical outlet cover plates. The court found that the district court erred in construing the term "joined" in claim 1 of the '324 patent too narrowly at summary judgment, reversing non-infringement on that claim and remanding with instructions to grant partial summary judgment of infringement. However, the court affirmed summary judgment of non-infringement on claim 11 of the '180 patent and other asserted claims, concluding that genuine disputes of material fact did not exist as to those claims.

The court's analysis centered on whether the district court improperly narrowed claim terms beyond their plain and ordinary meaning. For "joined," the court held that the specification's broad examples of attachment techniques—including adhesive, press fit, and snap fit—demonstrated breadth rather than limitation, and that nothing in the intrinsic record supported distinguishing "joined" from "support" to require some unspecified additional mechanical fastening beyond the contact being held in place through a hole by a rear cover. For "configured to," the court applied the parties' agreed construction of "designed to" and held that evidence of capability to contact receptacle box walls in outlier narrow boxes did not create a factual dispute where the product was not designed to do so in standard boxes.

The Federal Circuit vacated and remanded the district court's denial of Simon Property Group's motion to preserve its state-law indemnification claim against Blackhawk Network, which arose from AlexSam's infringement suit concerning U.S. Patent No. 6,000,608 covering multifunction gift card systems. After the district court granted summary judgment of noninfringement and entered an amended final judgment stating that all counterclaims and other claims "not previously ruled on are hereby DENIED-AS-MOOT," Simon filed a motion styled under Rule 60(a) seeking to clarify that its third-party indemnification claim against Blackhawk had not been mooted. The district court denied the motion, concluding that the broad mootness language encompassed the indemnification claim.

The Federal Circuit held that Simon's motion, though labeled as Rule 60(a), was properly construed as a Rule 60(b)(1) motion for relief from mistake, and that such relief was available because the motion was filed within the time for appeal and challenged a non-merits dismissal—precisely the circumstances where Rule 60(b) serves to prevent technical error from barring consideration of true merits. Applying Kemp v. United States, the court determined that the district court's erroneous conclusion that the indemnification claim was moot constituted judicial error cognizable under Rule 60(b)(1), as the parties maintained a live controversy over indemnification rights. Rather than remand for a mootness analysis, the court directed dismissal without prejudice under 28 U.S.C. § 1367(c) based on the parties' agreement that declining supplemental jurisdiction over the state-law claim was appropriate.