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August Technology Corp. v. Camtek, Ltd.

Citation: 395 F. App'x 692Docket: No. 2010-1458

Court: Court of Appeals for the Federal Circuit; September 20, 2010; Federal Appellate Court

Narrative Opinion Summary

In this case, Camtek, Ltd. sought a partial stay of a permanent injunction issued by the U.S. District Court for the District of Minnesota. This injunction followed a jury's finding that Camtek's Falcon® wafer inspection system infringed on U.S. Patent 6,826,298, owned by August Technology Corporation. The jury further determined that the patent was neither obvious nor invalid. The injunction barred Camtek from manufacturing, using, selling, or offering the Falcon machines or similar products in the United States and from practicing the method specified in claim 3 of the patent. Additionally, Camtek was restricted from communicating with potential U.S. buyers regarding these machines. Camtek's attempt to modify this injunction was denied, prompting it to seek a partial stay pending appeal. For such a stay, Camtek needed to demonstrate a strong likelihood of success on the merits or that the balance of harms was in its favor. After reviewing the submissions, the court found that Camtek did not meet these criteria and denied the motion for a partial stay. The ruling underscores the stringent standards for altering injunctive relief post-verdict, emphasizing the importance of the equities involved in such decisions.

Legal Issues Addressed

Evaluation of Equities in Stay Requests

Application: The court considered the equities affecting the parties and the public, ultimately determining that Camtek did not fulfill the necessary burden to justify a partial stay.

Reasoning: The court evaluates the movant's chances of success and the equities affecting the parties and the public.

Patent Infringement and Injunctions

Application: The court issued a permanent injunction against Camtek, Ltd. after a jury found that its Falcon® wafer inspection system infringed on a patent held by August Technology Corporation, prohibiting specific actions related to the product in the U.S.

Reasoning: The permanent injunction prohibits Camtek from manufacturing, using, selling, or offering to sell Falcon machines or similar products in the U.S., and from practicing the method outlined in claim 3.

Standards for Granting a Stay of Injunction Pending Appeal

Application: Camtek's request for a partial stay pending appeal was denied because it failed to demonstrate a strong likelihood of success on the merits or that the balance of harms favored its position.

Reasoning: In seeking a partial stay pending appeal, Camtek must demonstrate either a strong likelihood of success on the merits of its case or a substantial case on the merits with harm factors in its favor.