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Hydranautics v. Filmtec Corp.
Citation: 224 F. App'x 675Docket: No. 06-55182
Court: Court of Appeals for the Ninth Circuit; March 16, 2007; Federal Appellate Court
Hydranautics appeals the district court's summary judgment in favor of FilmTec Corporation regarding claims of malicious prosecution and antitrust violations. The appellate court affirms the lower court's ruling. Hydranautics' malicious prosecution claim is dismissed because FilmTec had probable cause when it initiated a patent infringement lawsuit against Hydranautics. A previous ruling established that, barring fraud or perjury, a presumption of probable cause arises once the defendant wins an underlying case, which Hydranautics failed to rebut with any evidence of misconduct by FilmTec. Consequently, the failure to refute the presumption of probable cause also undermines Hydranautics' antitrust claim, which fails as a matter of law. The court confirms that a summary judgment is appropriate when no material fact disputes exist, and the moving party is entitled to judgment. Under California law, a malicious prosecution claim requires proof that the prior action was initiated without probable cause. The court reiterates that a favorable outcome in the original trial establishes probable cause, unless fraud or perjury is proven. The ruling indicates that a proper determination of probable cause negates the possibility of proving an antitrust claim based on sham litigation, thus granting FilmTec immunity under applicable legal precedents. The disposition is unpublished and not intended to serve as precedent.