Articles Posted in District Courts

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In a significant development for declaratory judgment actions involving jurisdictional challenges, a Northern District of California Magistrate Judge has ruled in favor of Samsung Electronics in its ongoing dispute with CM HK Ltd. The order from the court resolves key discovery issues, compelling document production from shared corporate resources and additional depositions to probe alter ego allegations. This ruling highlights the scrutiny courts apply to intertwined corporate structures in patent litigation, particularly when personal jurisdiction is at stake.

The case centers on Samsung’s bid for declaratory relief against CyWee Group Ltd.’s patent claims related to motion-sensing technology. After dismissing CyWee voluntarily and granting CM HK’s motion to dismiss for lack of personal jurisdiction, Judge Tigar allowed amendment and limited jurisdictional discovery focused on Samsung’s alter ego theory—that CM HK operates as CyWee’s extension in California, justifying jurisdiction via CyWee’s California contacts.

Under California law, alter ego requires unity of interest and ownership, plus a risk of injustice from treating entities separately. Relevant factors include commingling of assets, shared employees and offices, and disregard of corporate formalities. Judge Tigar noted colorable claims of asset manipulation between CM HK and CyWee, warranting discovery into their relationship.

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In a post-judgment ruling from the U.S. District Court for the Eastern District of New York, the court rejected defendants’ bid to escape a destruction mandate after the asserted patents expired just days after a permanent injunction issued, ordering the destruction of all infringing “RadCad caddies” in defendants’ possession during the patent term. The decision affirms courts’ equitable powers to remedy past infringement even post-expiration of a patent, citing Federal Circuit precedents to distinguish between impermissible future-use bans and status quo restorations like product destruction.

Background

Following a finding of willful infringement, the court on August 29, 2025, entered a Permanent Injunction Order (“PI Order”) enjoining defendants from making, using, selling, or offering to sell infringing RadCad caddies—battery-powered medical transport devices—and requiring, at defendants’ expense, the destruction of all such products in their possession or control (the “Destruction Order”). The PI Order specified it would “remain in effect until the expiration of the asserted patents” and mandated notification of compliance within 30 days.

Plaintiff notified the court on September 12, 2025, that the patents expired on September 2, 2025—mere days after the PI Order. Defendants moved for confirmation that the expiration of the patent nullified all obligations, including destruction and reporting, arguing the court lacked post-expiration equitable authority. Plaintiff countered that the patents’ lapse didn’t moot remediation for past wrongs. The court, balancing the PI Order’s terms with enduring jurisdiction, sided with plaintiff.

Key Issues in the Decision

The court’s analysis hinged on the interplay between the PI Order’s explicit expiration tie and broader equitable remedies for infringement.

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In Anonymous Media Research Holdings, LLC v. Samsung Electronics Co., Ltd. (No. 2:23-CV-00439-JRG-RSP, E.D. Tex. Sept. 17, 2025), the U.S. District Court for the Eastern District of Texas denied Samsung’s motion to exclude the apportionment opinions of plaintiff’s expert, Mr. W. Leo Hoarty. The ruling, by Magistrate Judge Roy S. Payne, underscores the court’s gatekeeping role under Daubert while affirming that methodological critiques—such as alleged inclusion of prior art value or equal-weight assumptions—typically go to the weight of evidence, not admissibility. This decision in a multi-patent infringement suit over automatic content recognition (ACR) technology highlights the latitude afforded technical experts in royalty calculations, particularly when grounded in defendant-specific data.

Background

AMRH accuses Samsung of infringing four patents (Nos. 9,942,434; 10,244,180; 10,484,503; and 11,238,363) covering ACR systems for fingerprinting and matching media content to enable targeted ads and analytics in smart TVs. Hoarty, a technical expert, opined on apportionment, starting from Samsung’s “Matching and Analytics Servers” costs, counting infringing sub-features (e.g., fingerprint databases), and applying a weighted apportionment rate tied to Samsung’s internal allocations and his expertise.

Samsung sought exclusion under Fed. R. Evid. 702 and Daubert, arguing Hoarty’s analysis failed to isolate the patents’ incremental value over prior art, used an unreliable feature-counting method, applied a one-size-fits-all rate across patents, and ignored total ACR costs. After briefing, the court denied the motion.

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In a recent decision from the U.S. District Court for the Northern District of Georgia, the Court granted motions to dismiss and for judgment on the pleadings, invalidating two patents related to software for detecting cheating in the card game bridge. The ruling underscores the ongoing challenges for software patents under 35 U.S.C. § 101, particularly those involving data collection and analysis. The court applied the two-step Alice framework to find the patents directed to an abstract idea without an inventive concept, highlighting the limits of patenting mathematical techniques even in niche applications.

Background

This case centers on patents for technology designed to detect cheating in bridge, a trick-taking card game with over 165,000 professional members in North America. Plaintiff, The EDGAR Association (“EDGAR”), owns and developed a competing system called EDGAR (Everyone Deserves a Game Above Reproach), which uses data analysis to generate reports on potential cheating. EDGAR filed suit seeking declaratory judgments that U.S. Patent Nos. 11,014,005 (the “‘005 Patent”) and 11,439,912 (the “‘912 Patent”)—owned by Defendants Nicolas Hammond and Hammond Software, Inc. (collectively, the “Hammond Defendants”)—are invalid and not infringed.

The ‘005 Patent, titled “Detecting Cheating and Changes in Playing Ability in Partial Knowledge and Trick-Taking Games,” issued on May 25, 2021, contains 20 claims, including three independent claims. The ‘912 Patent, a continuation of the ‘005 Patent, issued on September 13, 2022, shares a substantially identical specification. Both patents claim methods, systems, and computer equipment for detecting cheating by: (1) acquiring board data from bridge games (e.g., hand records, table results, contracts, and declarers); (2) determining performance values for players; (3) detecting deviations by comparing values against thresholds based on past cheating or optimal behavior; and (4) alerting administrators via electronic message.

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Recent Decision Highlights Discoverability of Funding Arrangements

In a recent discovery dispute in the Northern District of California, Judge Sallie Kim has ordered the plaintiff to produce litigation funding agreements, finding them relevant to potential witness bias. The April 29, 2025 order in Correct Transmission, LLC v. Juniper Networks Inc (Case No. 21-cv-09284-RFL) provides important guidance on when litigation funding arrangements may be discoverable despite work product protection claims.

Case Background

The case involves patent infringement claims brought by Correct Transmission against Juniper Networks. The patents-in-suit have an interesting ownership history, having changed hands multiple times before the current litigation:

  • Originally owned by Orckit Communications (co-founded by CEO Izhak Tamir)
  • After liquidation, purchased by Orckit IP in 2015 (funded by Tamir)
  • Later assigned to Correct Transmission for enforcement and licensing
  • Correct Transmission then entered into litigation funding agreements to monetize the patents

The dispute centered on whether these litigation funding agreements should be produced to the defendant.

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A federal court in Massachusetts has granted in part a motion for permanent injunction against defendants found liable for misappropriating trade secrets related to an insulin patch pump, imposing several significant remedies including the reassignment of patent applications that incorporate the intellectual property.

The case centered on Insulet Corporation’s Omnipod insulin delivery system, where after a month-long trial, a jury found six defendants liable for misappropriating trade secrets in violation of the Defend Trade Secrets Act (DTSA). The jury awarded Insulet $452 million, consisting of $170 million in unjust-enrichment damages and $282 million in exemplary damages. However, the court ultimately reduced the total damages award to $59.4 million to avoid potential double recovery issues with the injunctive relief.

The court’s April 24, 2025 ruling in Insulet Corporation v. EOFlow Co., Ltd. et al. follows a jury verdict that found the defendants liable for misappropriating four trade secrets belonging to Insulet Corporation, including an occlusion-detection-algorithm (ODA). When addressing Insulet’s request for reassignment of patent applications incorporating aspects of the misappropriated trade secrets, the court explained:

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In a recent decision from the United States District Court for the District of Massachusetts, the district court denied Abbott Laboratories’ motion for summary judgment in a patent infringement case involving multiple pharmaceutical companies. This ruling offers valuable insights into the application of Rule 19 joinder requirements in patent litigation.

The Case: Chr. Hansen HMO GmbH v. Glycosyn LLC

The dispute centers on a patent infringement claim brought by Glycosyn LLC against Abbott Laboratories, with Chr. Hansen HMO GmbH also involved as a plaintiff and counterclaim-defendant. Abbott argued that Glycosyn could not maintain its patent infringement suit without joining another company, Friesland Campina DOMO B.V. (“RFC”), which allegedly had an exclusive licensing agreement with Glycosyn for the patents at issue.

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In a recent discovery dispute in a patent infringement case, the district court denied the defendant’s motion to compel the plaintiff to produce certain inventor emails that were withheld on the basis of the work product doctrine. The key issue was whether the plaintiff demonstrated that the emails, exchanged between the two inventors of the asserted patents from 2016-2018, were prepared in anticipation of litigation. The litigation ultimately commenced in February 2022.

The district court acknowledged that evidence pointed to by both sides benefitted their respective positions–the defendant highlighted facts suggesting the inventors’ work was not in anticipation of litigation, while the plaintiff provided contrary evidence. Ultimately, the district court found the plaintiff’s showing sufficient to meet its burden and justify the work product protection.

Key evidence cited by the district court included:

  1. An inventor’s testimony that he began investigating potential infringement in November 2015 with the assistance of outside counsel.
  2. The inventor provided information to outside counsel from 2016-2020 to assess possible infringement.
  3. Starting November 2015, the inventor implemented measures to preserve documents related to the patents and defendant.
  4. Testimony from the outside attorney that he had previously advised the plaintiff about potential litigation involving the patents at issue.

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In the ongoing case of Inmar Brand Solutions, Inc. v. Quotient Technology Inc., the district court was tasked with conducting an analysis under the Supreme Court’s two-step test in Alice Corp. v. CLS Bank International to determine whether Inmar’s patented coupon-processing system, exclusively licensed from Intelligent Clearing Network, Inc. (ICN), was entitled to patent protection. Under the Alice framework, the district court must first ascertain whether claims are directed towards patent-ineligible subject matter, such as abstract ideas. If so, the district court proceeds to the second step, wherein it evaluates whether the claims contain an inventive concept that transforms the abstract idea into a patent-eligible application.

Quotient contends that the patents asserted by Inmar are invalid and directed towards a patent-ineligible abstract idea: namely the processing of coupons on a remote server. According to Quotient, the claims lack an inventive concept and merely recite generic computer components.

Inmar opposes this characterization, and contends that the claims represent an improved coupon processing architecture that significantly reduces fraud and cannot be accomplished by humans.

As explained by the district court, the primary concern underlying this argument is the concept of preemption, which aims to prevent the granting of a monopoly over an abstract idea that could impede innovation. While the Supreme Court in Alice did not provide precise contours for what constitutes an abstract idea, subsequent Federal Circuit decisions have shed light on this issue. Continue reading

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The crux of this case revolves around a dispute over patent infringement, trade secret misappropriation, and unfair competition filed by Nielsen (or Plaintiff) against Hyphametrics (or Defendant). At the heart of the issue in this motion were specific documents – experimental reports. These reports were initially produced by Hyphametrics to Nielsen but were later retracted under the assertion of work product protection.

The Memorandum Order issued by the court dissected the arguments presented by both parties and presented the court’s rationale for its ruling on Nielsen’s motion to compel Hyphametrics to produce the disputed documents. The court began by addressing Hyphametrics’ intentional production of certain reports to Nielsen. Despite Hyphametrics’ claim that the documents were mistakenly believed to be unprotected by the work product doctrine, the court noted that the intentional release of these documents nullified any work product protection. The court emphasized that the mistaken belief in their protection status cannot serve as a valid basis for claiming inadvertent production.

The court explained that Defendant’s prior counsel (“prior counsel”) produced three reports at issue here to Plaintiff. “When prior counsel did so, it knew all of the facts one would need to know to understand that, under the law, those documents were protected by the work product doctrine. A document is protected by the work product doctrine if it is prepared in anticipation of litigation or trial by a party or its representative. Fed. R. Civ. P. 26(b)(3)(A). It is undisputed here that the reports fit this bill, and prior counsel knew this when they intentionally produced the reports.” As a result, the court concluded that Defendant therefore waived any work product protection for the reports by intentionally producing them here. Continue reading