Key IP Decisions
Federal Courts Navigate Complex IP Disputes, Limiting Anti-SLAPP in Unfair Competition Cases
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Key Points
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In Gratuity Solutions v. Toast, the Massachusetts court held that anti-SLAPP protections may not apply where the alleged coercive conduct includes pre-suit demand letters and other actions outside the courtroom, meaning a Chapter 93A claim can proceed based on unfair competition beyond petitioning activity.
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The Gratuity decision also highlights a 'commercial extortion' theory, evidencing the dispute where patent-infringement threats and related litigation were allegedly used to pressure Toast into an acquisition, with a 2022 demand letter cited as part of that coercive conduct.
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In Delaware, Beckman Coulter's motion for summary judgment was denied because the reverse doctrine of equivalents defense remains viable under thePatent Act of 1952 to limit claim scope, rather than being invalidated by the Act.
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In Texas, Magnolia Hospice won a preliminary injunction on the Magnolia Hospice mark, with the court finding likelihood of confusion and actual confusion in overlapping hospice service markets.
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The TrackTime LLC v. Amazon decision by the Federal Circuit partially affirmed and partially vacated/remanded; notably, the court reversed a portion of the district court’s invalidity ruling while upholding the denial of JMOL and a new trial, in a patent about mobile-device navigation within a multimedia file using a time-correlated transcript.
A Massachusetts federal court refused to fully dismiss a Chapter 93A counterclaim in Gratuity Solutions v. Toast, ruling that anti-SLAPP protections do not shield alleged coercive conduct that happens outside the courtroom — like pre-suit demand letters used as leverage in a business dispute, according to Bloomberg Law.
The ruling is one of several recent federal court decisions reshaping patent and trademark law across the country. Courts in Texas, Delaware, and California also issued significant rulings this week, and the Federal Circuit weighed in on a mobile navigation patent case involving Amazon.
Toast Faced 'Commercial Extortion' Claims Over Patent Threats
At the heart of Gratuity Solutions v. Toast is a 'commercial extortion' theory. Gratuity Solutions allegedly used patent-infringement threats and related litigation to pressure Toast — a restaurant technology company — into an acquisition, according to Bloomberg Law. A 2022 demand letter was cited as a key piece of that coercive conduct.
The court found that anti-SLAPP laws, which protect petitioning activity like filing lawsuits, may not cover actions taken outside the courtroom. That means Toast's Chapter 93A counterclaim — a Massachusetts unfair competition law — can move forward. The ruling signals that demand letters alone can be enough to sustain an unfair competition case.
Magnolia Hospice Wins Preliminary Injunction in Texas Trademark Fight
A Texas federal court granted Magnolia Hospice a preliminary injunction over its name and brand. The court found a likelihood of confusion and actual confusion in overlapping hospice service markets. A preliminary injunction means the competing use of the name must stop while the case plays out.
Trademark confusion cases require courts to weigh several factors, including how similar the marks are and whether customers are likely to mix up the two services. Here, the court found that bar was cleared — real-world confusion had already happened, which is a strong signal for Magnolia Hospice's full case ahead.
Federal Circuit Splits the Difference in Amazon Navigation Patent Case
The Federal Circuit issued a mixed ruling in TrackTime LLC v. Amazon. The patent at issue covers a way to navigate within a multimedia file using a time-correlated transcript on a mobile device — think jumping to a specific spoken word in a podcast. The appeals court partially affirmed the lower court's decision but reversed part of its invalidity ruling.
The court upheld the denial of judgment as a matter of law and a new trial, but sent part of the case back to the Delaware district court. The partial reversal on invalidity keeps TrackTime's patent claims alive for now, meaning Amazon's legal exposure in the case is not yet resolved.
Beckman Coulter Survives in Delaware; Gallo Wins Clean in California
In Delaware, Beckman Coulter — a medical diagnostics company — lost its motion for summary judgment against Cytek Biosciences. The court ruled that the reverse doctrine of equivalents remains a viable defense under the Patent Act of 1952. That doctrine can limit how broadly a patent applies, even when a product technically falls within a patent's written claims.
Meanwhile in California, E. & J. Gallo Winery won outright. A federal court granted Gallo summary judgment, finding both noninfringement and patent ineligibility in a dispute over automated crop irrigation patents. Patent ineligibility is a separate and harder-to-overcome hurdle — it means the ideas behind the patent were not the kind courts can protect at all, according to Bloomberg Law.
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