Northern California Courts Rule in Patent Cases

The water purification system at issue in Goodman Ball.

A few judges on the U.S. District Court for the Northern District of California recently released opinions in patent cases.

Goodman Ball, Inc. v. Mach II Aviation is a patent infringement and breach of contract action relating to water purification systems imported from Australia and sold to the U.S. Navy.  After learning about the sale, Goodman sued and the case settled.  After the settlement, another company, Solar Diesel, sold several of the units at a bankruptcy sale.  As Judge Alsup explains,

Given these shenanigans, in December 2008, plaintiff moved to reopen the prior litigation pursuant to FRCP 60(b), alleging (among other things) that defendants’ conduct in “settling” the prior action had amounted to fraud.

Judge Alsup stated that the patent infringement suit had already been argued and he would not allow the parties to relitigate it, however, he would allow the breach of contract claim into discovery.  He granted the motion to dismiss in part and denied it in part.

The Seiko Projector Patent

Seiko Epson Corp. v. Coretronic Corp. is back to the Northern District of California on remand from the Court of Appeals for the Federal Circuit.  The present matter asks whether Seiko's U.S. Patent No. 6,203,158 for a cooling system for a video projector is obvious (and therefore invalid) in view of Japanese Patent Application No. 4-271334, and U.S. Patent No. 5,297,005. Judge Marilyn Hall Patel explained:

To determine the issue of non-obviousness, it will often be necessary for a court “to look tointerrelated teachings of multiple patents; the effects of demands known to the design community orpresent in the marketplace; and the background knowledge possessed by a person having ordinary skill in the art,” in order to determine “whether there was an apparent reason to combine the known elements in the fashion claimed by the patent at issue.” [KSR Int’l Co. v. Teleflex Inc. (U.S. 2007)].

The Cooling System in the Gourdine Patent

Seiko argues that combining the Japanese application and the '005 patent would not lead the projector in question because a person who combined them would obtain unstable results.  Judge Patel didn't think that mattered:

Gourdine’s [the '005 patent] teaching that isolating a predetermined heat-generating component improves cooling of that component has obvious benefit for a projector designer looking to more efficiently cool theprojector power supply. Some alterations might be necessitated in applying Gourdine’s teachings tothe projector disclosed by Nakamura [the Japanese application], but “a person of ordinary skill often will be able to fit theteachings of multiple patents together like pieces of a puzzle.” Id.

She granted summary judgment (again) for Coretronic.

In Myspace v. Graphon Corp. and Craigslist v. Graphon Corp., the plaintiffs have filed a declaratory judgment action seeking invalidity of a series of patents that cover a method and apparatus that enable a user to create, modify and/or search for a database record over a computer network.  The plaintiffs argue that the Mother of all Bulletin Boards (MBB) either anticipated or made obvious every element in the claims of the patents that Graphon owns.  Judge Elizabeth D. Laporte agreed:

There is no dispute that MBB is prior art. The first filing date of the asserted patents is December 14, 1995. The MBB was in public use by at least April 1994, more than one year prior tothe date of the application of the asserted patents.

She found the patents were anticipated by MBB and granted summary judgment for the plaintiffs.