Railware, Inc. v. National Railroad Passenger Corporation
- Katherine Failla
- 1:22-cv-05013
- U.S. District Court · Southern District of New York
- 5
In Railware v. National Railroad, Judge Failla ordered Railware to provide Amtrak a claim chart and extended two case deadlines.
Railware must provide Amtrak a claim chart by April 5, 2024. The order also changes two case deadlines affecting both parties.
What happened
Railware, Inc. v. National Railroad Passenger Corporation concerns Amtrak’s request to strike Railware’s two-page patent-infringement contentions. Railware had identified 60 claims and two accused products.
The parties disagreed about whether the Southern District of New York’s local patent rule required detailed claim charts. Railware argued that the rule required only identifying the asserted claims and accused products; Amtrak argued that more detail was necessary.
The court ordered Railware to provide Amtrak a claim chart by April 5, 2024, and extended two related deadlines. Judge Failla did not expressly state that the motion was granted or denied; the clerk was directed to terminate the pending motion.
The detailed version
- Railware, Inc. v. National Railroad Passenger Corporation · No. 1:22-cv-05013
- Katherine Failla
- Mar. 20, 2024
Background
Railware served two-page infringement contentions on February 29, 2024. The contentions identified the patent claims Railware asserted and the products it alleged infringed those claims. Amtrak requested an order striking the contentions. Railware opposed the request, arguing that Local Patent Rule 6 did not require claim charts before discovery and that its contentions complied with the rule.
Issue
The court addressed whether Railware should be required to provide claim charts—documents that match the elements of each asserted patent claim to the accused products. The court noted that the parties disputed whether this level of detail was an inherent requirement of the Southern District’s local rule. The court also noted that the local patent rules give it discretion to modify the parties’ obligations based on the circumstances of a particular case.
Ruling
The court found that requiring a claim chart was appropriate in this case because Railware’s contentions were sparse, consisting of two pages, and Railware asserted 60 claims against two accused products. The court ordered Railware to provide the chart to Amtrak by April 5, 2024.
The court extended the deadline for serving invalidity or unenforceability contentions from April 16 to April 29, 2024. It extended the deadline for exchanging proposed claim-construction terms from April 18 to May 1, 2024. The court declined to make further changes to the case-management plan and scheduling order at that time.
The order did not expressly say that Amtrak’s motion was granted or denied. Instead, it directed the clerk to terminate the pending motion at docket entry 94.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.