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Envirotech Corporation v. Amstar Corporation, and Enviro-Clear Company, Inc.
Citation: 48 F.3d 1237Docket: 93-1162
Court: Court of Appeals for the Federal Circuit; April 18, 1995; Federal Appellate Court
Federal Circuit Local Rule 47.6(b) clarifies that opinions and orders not designated as citable precedent cannot be cited as such, though they may still inform issues like claim preclusion or judicial estoppel. In the case of Envirotech Corporation v. Amstar Corporation, Envirotech appealed a District Court ruling that dismissed its suit for relief from a prior judgment concerning a $5 million payment for infringement of U.S. Patent No. 3,523,889. The court upheld the dismissal, noting that Amstar had successfully argued infringement since 1979 and that Envirotech's attempts to challenge the patent's validity through reexamination were ultimately unsuccessful, as the PTO confirmed the patent's validity in 1987. Envirotech's claims of Amstar's inequitable conduct in the reexamination were found to lack sufficient evidence to demonstrate material misrepresentation or intent to deceive, leading to the dismissal of its complaint. The court refrained from ruling on whether this conduct constituted "fraud on the court," as previous rulings established that inequitable conduct before the PTO does not qualify as such. Rule 60(b) of the Federal Rules of Civil Procedure allows for relief from a judgment under specific conditions, but does not limit the right to pursue a separate action for fraud upon the court. A motion to set aside a judgment, order, or proceeding must be filed within a reasonable time and no later than one year after the judgment's entry. Courts retain the authority to consider independent actions for relief from judgments or orders, including cases where a defendant was not properly notified or where there is evidence of fraud upon the court. Relief from a judgment can be sought either through a motion as outlined in procedural rules or via independent action. Rule 60(b) allows for setting aside a judgment for fraud, specifically addressing fraud upon the court under subsection (3), which has a one-year limitation. However, actions for fraud upon the court do not have a fixed time frame. The term "fraud upon the court" refers to fraud that corrupts the judicial process itself, rather than fraud between the parties. In the referenced case, Broyhill was found to have engaged in inequitable conduct with the Patent and Trademark Office (PTO), but this was not deemed fraud upon the court as per Rule 60(b). Consequently, even if Amstar's conduct were reversed, it would not justify setting aside the judgment. The argument that it would be inequitable to uphold the judgment based on Amstar's conduct is unsupported because inequitable conduct before the PTO does not equate to fraud upon the court. Therefore, the district court's decision is affirmed.