Golden v. Apple, Inc.
- Vince Chhabria
- 3:22-cv-04152
- U.S. District Court · Northern District of California
- 1
In Golden v. Apple, Judge Chhabria dismissed Golden’s frivolous patent and antitrust claims because prior litigation barred them and the antitrust allegations were implausible.
Larry Golden’s patent-infringement and antitrust claims against Apple, Inc. were dismissed without leave to amend.
What happened
In Golden v. Apple, Inc., Larry Golden sued Apple, Inc., asserting patent-infringement and antitrust claims. The opinion states that Golden had pursued these claims, or similar versions, for nearly 10 years in multiple jurisdictions.
Judge Chhabria concluded that the claims were frivolous. He also said the patent claims were barred because the issues had already been fully litigated and decided, and that the antitrust allegations did not plausibly show a conspiracy or the kind of injury antitrust laws address.
The court granted Apple’s motion to dismiss and dismissed the complaint without leave to amend. Judge Vince Chhabria said dismissal at the outset without allowing an amended complaint was appropriate in this unusual case.
The detailed version
- Golden v. Apple, Inc. · No. 3:22-cv-04152
- Vince Chhabria
- Oct. 20, 2022
Background
Larry Golden brought patent-infringement and antitrust claims against Apple, Inc. The court stated that Golden had been pressing these claims, or some variation of them, for nearly 10 years in multiple jurisdictions.
Court’s analysis
The court granted Apple’s motion to dismiss, finding that the claims in the complaint were frivolous. In the alternative, the court held that issue preclusion barred Golden’s patent claims. Issue preclusion is a rule that prevents a party from relitigating an issue that was fully litigated and decided in an earlier proceeding. The court cited an earlier proceeding involving Golden and the United States and stated that the patent claims had already been fully litigated and decided.
The court also held that Golden’s antitrust allegations failed to state a plausible claim. Specifically, it said Golden did not, and could not, plausibly allege either a conspiracy or an injury of the type antitrust laws were intended to prevent.
Disposition
The court dismissed the complaint without leave to amend, meaning the court did not allow Golden to file an amended complaint in this action. Judge Vince Chhabria stated that dismissal without leave to amend was appropriate at the outset because of the nature and history of the claims.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.