Decisions on Declaratory Relief and Jursidictional Issues in Patent Cases
The Federal Circuit decided two cases involving patent infringement and requests for declaratory relief.
In Delaware Valley Floral Group, Inc. v. Shaw Rose Nets, LLC, No. 09-1357, the court faced a challenge to the district court's grant of plaintiff's motion seeking declaratory relief against an inventor and owner of a patent relating to a process for producing larger rose heads by placing elastic, porous nets over the rose heads during the growing process.
In affirming the district court's decision to grant declaratory relief based on the on-sale bar under section 102(b), the court held that the inventor-owner failed to raise a genuine issue of material fact surrounding the dates of conception or commercial sales, and also that the defendant failed to show any error by the district court in disregarding the evidence presented in its motion for reconsideration.
In Lab. Corp. of Am. Holdings v. Metabolite Labs., Inc., No. 08-1597, the court dealt with whether it had jurisdiction over the district court's grant of summary judgment in favor of the plaintiff in its action for a declaratory relief that it did not breach a license agreement for failure to pay know-how royalties after judgment had been entered in a prior patent infringement and breach of contract action.
In holding that it lacked jurisdiction, the court concluded that the present cause of action does not arise under federal patent law nor does defendant's right to relief necessarily depend on resolution of a substantial question of federal patent law. Thus, the court lacks jurisdiction as the action is a state law contract dispute over know-how royalties brought pursuant to the district court's diversity jurisdiction.
- Full text of Delaware Valley Floral Group, Inc. v. Shaw Rose Nets, LLC
- Full text of Lab. Corp. of Am. Holdings v. Metabolite Labs., Inc