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In Re Sgs-Thomson Microelectronics, Inc.

Citations: 61 F.3d 862; 35 U.S.P.Q. 2d (BNA) 1639; 1995 U.S. App. LEXIS 20023; 1995 WL 447464Docket: 428

Court: Court of Appeals for the Federal Circuit; July 25, 1995; Federal Appellate Court

Narrative Opinion Summary

The case involves a patent infringement dispute between International Rectifier and SGS-Thomson Microelectronics, Inc. International Rectifier initiated the suit seeking an injunction, while SGS-Thomson counterclaimed for a declaratory judgment on noninfringement, invalidity, and unenforceability, and demanded a jury trial. The district court sided with International Rectifier and struck the jury demand. SGS-Thomson then sought a writ of mandamus from the United States Court of Appeals for the Federal Circuit to reinstate its jury trial demand. On April 25, 1995, the appellate court partially granted the petition, reinstating the jury trial demand for the non-equitable claims. International Rectifier attempted to secure a rehearing en banc; however, this request was denied after a poll among the judges. A dissent was filed by Circuit Judge Nies, who was joined by Chief Judge Archer and Circuit Judge Plager, indicating a disagreement with the denial of the en banc rehearing and referencing a prior related dissent. The case exemplifies the procedural complexities in patent litigation and the appellate process, particularly concerning the right to jury trials and the en banc rehearing mechanism.

Legal Issues Addressed

En Banc Rehearing Procedures

Application: Despite International Rectifier's request and the subsequent judicial poll, the appellate court denied the rehearing en banc, showcasing the procedural requirements and judicial discretion in such decisions.

Reasoning: Subsequently, International Rectifier requested a rehearing en banc, which was denied. The court circulated the suggestion for rehearing and the response from SGS-Thomson among judges, resulting in a failed poll for rehearing.

Judicial Dissent in Appellate Decisions

Application: Circuit Judge Nies, along with two other judges, dissented from the denial of the en banc rehearing, referencing a related dissent, highlighting the role of dissent in judicial decision-making.

Reasoning: Circuit Judge Nies dissented from the denial, joined by Chief Judge Archer and Circuit Judge Plager, referencing his prior dissent in a related case, In re Lockwood.

Mandamus Relief in Federal Appeals

Application: SGS-Thomson successfully sought mandamus relief to obtain a jury trial, demonstrating the appellate court's willingness to intervene in the district court's procedural rulings.

Reasoning: SGS-Thomson petitioned for a writ of mandamus to compel the district court to allow a jury trial on its counterclaims.

Right to Jury Trial in Patent Litigation

Application: SGS-Thomson sought a jury trial for its counterclaims of noninfringement, invalidity, and unenforceability, but the district court initially struck the demand. The appellate court partially reinstated the jury demand, except for the equitable claim.

Reasoning: SGS-Thomson petitioned for a writ of mandamus to compel the district court to allow a jury trial on its counterclaims. On April 25, 1995, the appellate court granted the petition in part, ordering the reinstatement of the jury demand except for the equitable claim of unenforceability.