Narrative Opinion Summary
In this legal proceeding, Blue Coat Systems, Inc. moved to strike Finjan, Inc.'s infringement contentions related to several patents, asserting that these claims were precluded by prior litigation between the parties. The case follows an earlier suit, Blue Coat I, where Finjan successfully proved infringement on several patents. Blue Coat argued that the current claims were impermissible collateral attacks on the previous denial of amendments to infringement contentions and were barred by res judicata. Finjan countered that many products were new or had undergone significant changes since the initial litigation. The court ruled that while res judicata barred claims against certain previously accused products, it did not preclude actions concerning new or modified products introduced after the initial lawsuit. The doctrine of claim-splitting further limited Finjan's ability to pursue claims against products involved in Blue Coat I. Ultimately, the court partially granted Blue Coat's motion, striking some claims but allowing others to proceed, particularly those involving new products not addressed in the prior suit. The court emphasized the need for Finjan to amend its infringement contentions according to Patent Local Rule 3-1, ensuring specificity and relevance to the current litigation context.
Legal Issues Addressed
Claim-Splitting Doctrinesubscribe to see similar legal issues
Application: The court barred Finjan's claims against certain products based on claim-splitting, as these products were involved in previous litigation.
Reasoning: The court finds that claim-splitting bars Finjan’s claims against ProxySG and CAS with MAA since they were accused in Blue Coat I and involve the same combination of products.
Collateral Attack on Prior Court Orderssubscribe to see similar legal issues
Application: Finjan's new action was not considered an impermissible collateral attack on the previous court's denial of amendments to infringement contentions.
Reasoning: The court finds that Finjan's situation aligns more closely with Fujitsu than Icon, concluding that the order in Blue Coat I does not prevent Finjan from accusing Blue Coat’s products in future lawsuits.
Kessler Doctrinesubscribe to see similar legal issues
Application: The Kessler doctrine did not apply to products previously found to infringe, allowing Finjan to pursue claims on new versions of products.
Reasoning: The Kessler doctrine prevents suits against products adjudged as non-infringing but does not apply to products previously found to infringe.
Motion to Strike under Federal Rules of Civil Proceduresubscribe to see similar legal issues
Application: The court partially granted Blue Coat's motion to strike Finjan's infringement contentions as they were deemed irrelevant to the current proceedings.
Reasoning: The court partially granted and partially denied Blue Coat Systems, Inc.'s motion to strike Finjan, Inc.'s infringement contentions concerning U.S. Patent Nos. 6,154,844, 6,956,968, and 7,418,731.
Res Judicata in Patent Infringement Casessubscribe to see similar legal issues
Application: The court determined that res judicata precluded Finjan's claims regarding previously accused products but allowed claims for new products not involved in prior litigation.
Reasoning: The doctrine of res judicata applies when there is (1) an identity of claims, (2) a final judgment on the merits, and (3) identity or privity between parties, with the second and third elements undisputed in this case.