Monday, May 18, 2020

CAFC vacates ND Ga entry of summary judgment in ROTHSCHILD CONNECTED DEVICES v. Coca Cola

RCDI won its appeal at the CAFC:

For the foregoing reasons, we
reverse the district court’s claim construction of “user interface module,”
vacate the district court’s entry of summary judgment of noninfringement, and remand for
further proceedings.3 RCDI raised a number of discovery related issues on appeal.
On remand, we expect that the
district court will hold a new case management conference
concerning discovery

Of the "inherent authority" argument:

RCDI argues that the district court abused its discretion in exercising its inherent authority to dismiss the case
as to the dependent claims. We agree.

The district court’s analysis rests on a faulty premise:
that RCDI consistently refused to identify the dependent
claims it was asserting. In fact, on March 17, 2016—fewer
than five months into the case and before the case was
transferred from the Southern District of Florida to the
Northern District of Georgia—RCDI disclosed the asserted
dependent claims in its proposed amended complaint. J.A.
356; see also J.A. 348–58; J.A. 131–44. Although this motion was not ruled on for many months, that delay was
through no fault of RCDI.


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