Grecia v. Samsung Electronics America, Inc.
- Valerie Caproni
- 1:19-cv-03278
- U.S. District Court · Southern District of New York
- 4
In Grecia v. Samsung Electronics America, Judge Caproni denied William Grecia’s request to reconsider an earlier dismissal involving patent claims.
William Grecia and the defendants in the five related cases, including Samsung Electronics America, Inc.
What happened
In Grecia v. Samsung Electronics America, Inc., William Grecia asked the court to reconsider its earlier decision granting materially identical motions to dismiss in five related cases. He filed a reconsideration motion in each case.
Grecia argued that a new Federal Circuit decision changed the controlling law, that the court made an important error involving the meaning of a claim term, and that the court’s analogy to military-base access was mistaken. The court rejected these arguments and said his remaining arguments repeated points already made.
Judge Valerie Caproni denied Grecia’s motions for reconsideration and directed the Clerk of Court to close all open motions in the related cases. The court said it would issue an amended opinion correcting a footnote and clarifying one statement about the scope of a patent claim.
The detailed version
- Grecia v. Samsung Electronics America, Inc. · No. 1:19-cv-03278
- Valerie Caproni
- Apr. 24, 2020
Background
The order covers five related cases brought by William Grecia against Bank of New York Mellon Corporation, Citibank, N.A., Morgan Stanley Smith Barney LLC, TIAA, FSB doing business as TIAA Bank, and Samsung Electronics America, Inc. The court stated that, on March 13, 2020, it had granted the defendants’ materially identical motions to dismiss. On March 27, 2020, Grecia moved for reconsideration in each case.
Arguments and analysis
The court explained that reconsideration is available only when a party identifies a change in controlling law, new evidence, or a need to correct clear error or prevent serious injustice. Grecia argued that the Federal Circuit’s decision in Illumina, Inc. v. Ariosa Diagnostics, Inc. was an intervening change in controlling law. The court disagreed, concluding that Illumina was, at most, potentially persuasive authority and addressed claims directed to a natural phenomenon, unlike Grecia’s claim involving an abstract idea and interoperable digital access.
Grecia also argued that the court had mistakenly substituted the construction of “verified web service” for “verified web service account identifier.” The court said the mistake appeared in a footnote, was immaterial, and did not affect the court’s analysis. The court stated that it would issue an amended opinion correcting that error and revising a statement about Claim 1’s coverage of ways to store information. The court also rejected Grecia’s challenge to the court’s illustrative analogy involving an authorized user accessing a military base, and said his other arguments repeated arguments made in opposition to the original dismissal motions.
Ruling
Judge Valerie Caproni denied Grecia’s motions for reconsideration. The order does not state that the motions were denied with or without prejudice. The Clerk of Court was directed to close all open motions in the above-captioned cases.
Classification basis
This is a procedural order because the court denied reconsideration of an earlier ruling rather than deciding the underlying patent dispute anew. The order addressed whether reconsideration was warranted and did not grant reconsideration or change the earlier dismissal ruling.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.