Niazi Licensing Corporation v. Boston Scientific Corp.
- Wilhelmina Wright
- 0:17-cv-05094
- U.S. District Court · District of Minnesota
- 2
In Niazi Licensing v. Boston Scientific and St. Jude, Judge Wright denied leave to seek reconsideration of a claim-construction order.
Niazi Licensing Corporation’s requests for permission to seek reconsideration were denied in its cases against Boston Scientific Corp. and St. Jude Medical S.C., Inc.
What happened
In Niazi Licensing Corporation v. Boston Scientific Corp. and Niazi Licensing Corporation v. St. Jude Medical S.C., Inc., Niazi asked for permission to file motions reconsidering the Court’s October 21, 2019 claim-construction order. Niazi argued that the order contained legal errors concerning whether certain patent claims were indefinite.
The Court said Niazi had not identified a clear legal error or presented newly discovered evidence. Instead, the letters repeated arguments already made during claim-construction briefing and disagreed with the Court’s conclusions. The Court also said reconsideration was not the proper way to raise new arguments or legal theories.
Judge Wilhelmina M. Wright denied Niazi’s requests for permission to file motions for reconsideration in both cases because Niazi had not shown the required compelling circumstances.
The detailed version
- Niazi Licensing Corporation v. Boston Scientific Corp. · No. 0:17-cv-05094
- Wilhelmina Wright
- Dec. 13, 2019
Background
Niazi Licensing Corporation submitted October 30, 2019 letter requests for permission to file motions for reconsideration of the Court’s October 21, 2019 claim-construction order. The requests concerned the Court’s indefiniteness determinations. Under District of Minnesota Local Rule 7.1(j), a party may not file a motion for reconsideration without first obtaining leave of court.
Legal standard and analysis
The Court explained that reconsideration serves a limited purpose: correcting a manifest error of law or fact, or considering newly discovered evidence. A party must show compelling circumstances. Niazi did not claim to have newly discovered evidence. The Court concluded that Niazi’s letters identified no manifest legal error. Instead, they disagreed with the Court’s legal conclusions and repeated arguments that had already been presented in claim-construction briefing. The Court also stated that reconsideration is not a proper method for presenting new arguments or legal theories.
Ruling
The Court ordered that Niazi Licensing Corporation’s requests for leave to file motions for reconsideration—one in Case No. 17-cv-5094 and one in Case No. 17-cv-5096—are denied. Judge Wilhelmina M. Wright did not grant permission to file the proposed reconsideration motions.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.