Narrative Opinion Summary
In a patent infringement case, Silver State Intellectual Technologies, Inc. accused Garmin International, Inc. and Garmin USA, Inc. of infringing multiple patents related to navigation technologies. While some patents were dismissed, disputes continued over the '455, '992, '3812, and '039 Patents. Garmin counterclaimed for invalidity and non-infringement, and sought to amend its contentions post-claim construction, citing newly discovered prior art and differences in claim interpretation. The court found Garmin lacked diligence in amending its contentions, prejudicing Silver State, and struck Garmin's amendments. Garmin's motion for partial summary judgment was denied as it failed to prove the '992 Patent was anticipated by prior art or that its products did not infringe the '455 Patent based on a two-way communication requirement. The court found Garmin's interpretation of the '455 Patent, which included only two-way communications, was incorrect and did not impose such a limitation, allowing one-way communication claims to stand. The court emphasized the importance of timely and diligent disclosure of contentions under Local Patent Rules, ultimately ruling in favor of Silver State by striking Garmin's late amendments and denying summary judgment.
Legal Issues Addressed
Amendment of Patent Contentionssubscribe to see similar legal issues
Application: Garmin sought to amend its contentions post-claim construction, but the court found Garmin lacked diligence and the amendments would prejudice Silver State.
Reasoning: Garmin's late disclosure of pertinent contentions and prior art following an unfavorable claim construction ruling undermines its position.
Good Cause for Amending Patent Disclosuressubscribe to see similar legal issues
Application: The court ruled Garmin did not show good cause to amend its invalidity contentions as required by the Local Patent Rules after the court's claim construction order.
Reasoning: Garmin failed to demonstrate diligence in identifying these references or in seeking to amend its contentions after the court's claim construction order.
Infringement and Claim Constructionsubscribe to see similar legal issues
Application: Garmin failed to seek claim construction on the '455 Patent requiring two-way communication, and the court declined to impose this limitation, interpreting the claims to include one-way communication.
Reasoning: The Court declines to impose such a limitation on claim 1 of the '455 Patent.
Patent Infringement Under 35 U.S.C. § 102(b)subscribe to see similar legal issues
Application: Garmin argued that its product, Street-Pilot, and De-Lorme’s Map’n’Go 4.0 anticipated the '992 Patent, but failed to demonstrate that Map’n’Go 4.0 was sold or offered for sale before the critical date.
Reasoning: Garmin has not provided clear and convincing evidence of an actual sale or offer for sale related to Map’n’Go 4.0.
Standard for Summary Judgmentsubscribe to see similar legal issues
Application: Garmin's motion for partial summary judgment was denied due to insufficient evidence of an on-sale bar for Map’n’Go 4.0 and failure to establish non-infringement due to claim construction.
Reasoning: The Court denies Garmin’s Motion for Partial Summary Judgment concerning the on-sale bar associated with Map’n’Go 4.0.