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D. Minn.Procedural orderFiled Dec. 16, 2021

Niazi Licensing Corporation v. St. Jude Medical S.C., Inc.

Judge
Elizabeth Cowan Wright
Docket
0:17-cv-05096
Court
U.S. District Court · District of Minnesota
Pages
4
Intellectual PropertyCivil Procedure
In one sentence

In Niazi Licensing v. St. Jude, Judge Wright granted the joint motion and dismissed St. Jude’s patent-invalidity counterclaim without prejudice as moot.

Who this affects

Niazi Licensing Corporation and St. Jude Medical S.C., Inc.; the order dismissed St. Jude’s patent-invalidity counterclaim without prejudice as moot.

What happened

In Niazi Licensing Corporation v. St. Jude Medical S.C., Inc., the court had already ruled that St. Jude did not infringe the asserted patent claim. The only unresolved issue was St. Jude’s counterclaim arguing that the patent was invalid.

Both parties asked the court to dismiss that counterclaim without prejudice. They agreed that, after the non-infringement ruling, the counterclaim no longer presented a live dispute.

Judge Wilhelmina M. Wright granted the joint motion and dismissed St. Jude’s invalidity counterclaim without prejudice as moot. The order directed that judgment be entered.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Niazi Licensing Corporation v. St. Jude Medical S.C., Inc. · No. 0:17-cv-05096
Judge
Elizabeth Cowan Wright
Date
Dec. 16, 2021

Background

The court had previously granted St. Jude’s motion for summary judgment of non-infringement as to Claim 11 of Niazi Licensing Corporation’s United States Patent No. 6,638,268. Judgment was entered on March 24, 2021. St. Jude’s remaining invalidity counterclaim challenged the validity of that patent.

Niazi Licensing Corporation and St. Jude jointly moved to dismiss the invalidity counterclaim without prejudice. The court explained that, because it had found no infringement as to the sole remaining asserted patent claim, it had discretion to dismiss the invalidity counterclaim as moot rather than decide its validity issues. The court also noted that St. Jude could amend its answer to remove the counterclaim with Niazi Licensing Corporation’s consent, which had been provided.

Ruling

The court concluded that the invalidity counterclaim was moot because the parties no longer had a live controversy concerning it. Judge Wilhelmina M. Wright granted the parties’ joint motion to dismiss the counterclaim. The court ordered that St. Jude’s invalidity counterclaim be dismissed without prejudice as moot and directed that judgment be entered accordingly.

The authoritative version

Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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