ResApp Health recently announced its planned sale to Pfizer Australia, a wholly owned subsidiary of Pfizer Inc. Pfizer agrees it would acquire 100% of the shares for AUD $0.115 / share, for a total equity value of approximately AUD $100 million. ResApp directors announced a unanimous recommendation to sell, and their intent to vote their own shares accordingly. A shareholder vote is scheduled for June.

Cybellum released a medical device survey report on April 20, 2022 entitled “Medical Device Cybersecurity: Trends and Predictions.” The company’s website states that their “mission is to enable manufacturers and their suppliers to develop and maintain products that aren’t just safe, but are also secure.”

APPLE INC. v. ZIPIT WIRELESS, INC. [OPINION]- PRECEDENTIAL
Before Hughes, Mayer and Stoll. Appeal from the United States District Court for the Northern District of California.

Summary: Notice letters and related communications may be sufficient to establish personal jurisdiction within a given forum.

NIAZI LICENSING CORPORATION v. ST. JUDE MEDICAL S.C., INC.

Before Taranto, Bryson, and Stoll.  Appeal from the U.S. District Court for the District of Minnesota.

Summary: Providing examples in the claim language and written description may provide definiteness to descriptive terms.   

ROCHE DIAGNOSTICS CORPORATION v. MESO SCALE DIAGNOSTICS, LLC
Before Newman, Prost, and Taranto. Appeal from the U.S. District Court for the District of Delaware.

Summary: A finding of inducing infringement requires knowledge that the induced acts constitute patent infringement, which can be established by a finding of ‘willful blindness’, a standard of limited scope that surpasses recklessness and negligence.

LITTELFUSE, INC. v. MERSEN USA EP CORP.
Before Prost, Bryson, and Stoll. Appeal from the U.S. District Court for the District of Massachusetts.

Summary: The Federal Circuit vacated a claim construction that violated the doctrine of claim differentiation by eliminating the scope of several dependent claims.

GENUINE ENABLING TECHNOLOGY LLC V. NINTENDO CO., LTD

Before Newman, Reyna, and Stoll. Appeal from the Western District of Washington.

Summary: A finding of prosecution disclaimer must be supported by an unambiguous disavowal within the intrinsic record.

Last Friday, ImmunoGen won an appeal at the Federal Circuit in ImmunoGen, Inc. v. Hirshfeld. The lawsuit is a civil action to order the granting of U.S. Application No. 14/509,809 (‘809), titled “Anti-FOLR Immunoconjugate Dosing Regimens”:

Rasmussen Instruments, LLC (“Rasmussen”) won a $20M jury verdict against DePuy Synthes (“Depuy”), a part of Johnson & Johnson Medical Devices Companies. Rasmussen asserted Patent Nos. US 9,492,180 (‘180 patent) and US 10,517,583 (‘583 patent), both titled “Arthroplasty systems and methods for optimally aligning and tensioning a knee prosthesis,” against DePuy’s “Balanced Sizer” product for its Attune® Knee System.

ALMIRALL, LLC v. AMNEAL PHARMACEUTICALS LLC

Before Lourie, Chen, and Cunningham. Appeal from the Patent Trial and Appeal Board.

Summary: Presumption of obviousness based on overlapping ranges applied where a prior-art reference disclosed an element in the claimed range that was similar but not identical to the claimed element.