Narrative Opinion Summary
In this case, Ni-Q, LLC sought a declaratory judgment of non-infringement and invalidity concerning U.S. Patent No. 8,628,921, which involves testing methods for human donor milk. Ni-Q also pursued claims for damages and injunctive relief under Oregon's Unlawful Trade Practices Act. Defendant Prolacta Bioscience, Inc. asserted its patent rights and alleged infringement by Ni-Q. The court previously addressed patent term constructions and granted Ni-Q's motion for partial summary judgment, finding the patent claims invalid under 35 U.S.C. § 101 due to lack of patentable subject matter, and confirming no infringement occurred as Ni-Q did not perform all necessary steps of the patent claims. The court applied the Alice two-step framework to conclude that the patent claims were directed to non-patentable natural laws and lacked an inventive concept. Additionally, the court determined that Prolacta's infringement claims failed both literally and under the doctrine of equivalents, as Ni-Q did not conduct testing for unmatched markers required by the patent. Thus, the court ruled in favor of Ni-Q, concluding there were no genuine disputes of material fact regarding the patent's validity and non-infringement by Ni-Q.
Legal Issues Addressed
Doctrine of Equivalents in Patent Infringementsubscribe to see similar legal issues
Application: The court found insufficient evidence to establish infringement under the doctrine of equivalents, as Ni-Q did not test for unmatched markers in its processes.
Reasoning: Prolacta did not assert infringement under the doctrine of equivalents, and even if it did, there is insufficient evidence to establish equivalency, as required by patent law.
Infringement Analysis under Patent Lawsubscribe to see similar legal issues
Application: The court concluded that Ni-Q did not infringe the '921 Patent either literally or under the doctrine of equivalents, as it did not perform the required steps outlined in the patent claims.
Reasoning: Ni-Q contends it does not perform the 'wherein a match' step of the '921 Patent, asserting it has not literally infringed or infringed under the doctrine of equivalents.
Patent Eligibility under 35 U.S.C. § 101subscribe to see similar legal issues
Application: The court applied the two-step analysis from Alice Corp. v. CLS Bank to determine that the claims of the '921 Patent pertained to natural laws, specifically the identification of DNA and other identity markers in biological samples, which are not patent-eligible.
Reasoning: The Court concludes that the asserted claims pertain to natural laws, specifically the identification of DNA and other identity markers in biological samples, which occurs naturally in human tissue.
Summary Judgment Standardssubscribe to see similar legal issues
Application: The court granted summary judgment for Ni-Q, indicating that there were no genuine disputes of material fact and that Ni-Q demonstrated a lack of infringement and invalidity of the patent claims.
Reasoning: Summary judgment standards dictate that a party can be granted relief if there are no genuine disputes of material fact, emphasizing that the moving party bears the burden to demonstrate this lack of dispute.