Monday, August 01, 2016

CAFC in Murata: stay vs. preliminary injunction

From the decision


This is an interlocutory appeal from a patent infringement
lawsuit that Murata Machinery USA and
Murata Machinery, Ltd. (collectively “Murata”) filed
against Daifuku Co., Ltd. and Daifuku America Corp.
(collectively “Daifuku”) in the United States District
Court for the District of Utah. Daifuku petitioned for
inter partes review of all of the asserted patents, and the
district court then stayed the litigation. Murata moved to
lift the stay and for entry of a preliminary injunction, but
the district court denied the motions in a single order. We
hold that the district court did not err in refusing to lift
the stay, but that its cursory denial of the preliminary
injunction did not satisfy Rule 52(a)(2) of the Federal
Rules of Civil Procedure, which requires that a court state
findings and conclusions supporting denial of a preliminary
injunction. Thus, we affirm the district court’s order
as it pertains to the stay, but vacate the order with respect
to the preliminary injunction and remand for proceedings
consistent with this opinion

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