The U.S. Court of Appeals for the First Circuit is considering a legal malpractice lawsuit that tests the boundaries of attorney loyalty and professional conduct in patent law practice. BlueRadios, Inc., a Colorado corporation, is appealing a district court ruling in its case against the prominent Massachusetts intellectual property firm Hamilton, Brook, Smith & Reynolds, P.C., and six individual attorneys.

The case, *BlueRadios, Inc. v. Hamilton, Brook, Smith & Reynolds, P.C.* (1st Cir. 2026), centers on allegations that the law firm engaged in conflicted representation. In oral arguments before Circuit Judges Gelpí, Thompson, and Montecalvo, the court examined whether HBSR violated its duties to BlueRadios while representing other clients.

Judge Thompson opened the court's February 2 opinion by invoking the historical oath required of Massachusetts attorneys, emphasizing that lawyers must conduct themselves "with all good fidelity as well to the courts as" to their "clients." The judge noted that "today's case puts that assumption to the test," suggesting the significance of the professional responsibility issues at stake.

The dispute arose from HBSR's representation of BlueRadios in patent matters while simultaneously representing other clients with potentially conflicting interests. BlueRadios alleges this constituted a breach of the firm's fiduciary duties and professional obligations, describing the conduct as improper "two-timing" of clients.

Six individual attorneys from the firm are named as defendants alongside the firm itself. The case has drawn attention from the intellectual property community, with multiple amicus briefs filed to address the broader implications for patent law practice standards.

The First Circuit's eventual ruling is expected to provide important guidance on conflict of interest standards for patent law firms and may influence how intellectual property practitioners structure their client relationships and disclosure protocols.