Linfo IP, LLC v. American Exchange Apparel Group, Corp.

Background

Linfo IP, LLC brought a patent-infringement action against Aero Global, LLC, alleging infringement of U.S. Patent No. 9,092,428, referred to as the “’428 Patent.” Aero Global moved for judgment on the pleadings, arguing that the patent was invalid. A judgment on the pleadings is a ruling based on the parties’ pleadings when the material facts are not disputed and one side is entitled to judgment as a matter of law.

Issue Preclusion

The court noted that, in a prior related patent-infringement case brought by Linfo, Judge Furman held the ’428 Patent invalid. Linfo acknowledged that the prior invalidity ruling had preclusive effect. The court applied issue preclusion, which prevents a party from relitigating an issue that was already actually decided after that party had a full and fair opportunity to litigate it.

The court found that the prior case and this case involved the identical issue—the validity of the ’428 Patent. It also found that Judge Furman had decided that issue, Linfo had a full and fair opportunity to litigate it, and the decision was necessary to the prior judgment. The court therefore held that Linfo was barred from asserting infringement of the patent in this case.

Independent Merits Ruling

The court stated that Aero Global’s motion would also be granted on the merits even if issue preclusion did not apply. It adopted the reasoning and conclusion of the prior invalidity decision that the patent claims were directed to the abstract idea of extracting and presenting information. The court further agreed that representative claim 1 did not add an inventive concept to that abstract idea, making the claims ineligible for patent protection.

Disposition

The court granted Aero Global’s motion for judgment on the pleadings. The Clerk was directed to enter judgment dismissing Linfo’s claims with prejudice and to close the case.