The U.S. Court of Appeals for the Federal Circuit affirmed the International Trade Commission's final determination that certain optical networking devices did not infringe two patents, rejecting an appeal by pro se plaintiff Mark Sandstrom.
In the Jan. 9, 2026 nonprecedential decision in *Sandstrom v. International Trade Commission*, the Federal Circuit upheld the ITC's affirmation of an Administrative Law Judge's summary determination of no infringement and no violation of Section 337 of the Tariff Act of 1930.
The case centered on allegations that optical line termination devices and optical network terminal devices infringed U.S. Patent Nos. 10,567,474 and 10,848,546, both owned by Sandstrom. These devices are critical components in fiber optic networks, with OLT devices used by network service providers to split incoming optical signals into multiple signals for distribution to end users.
Sandstrom, representing himself pro se from Alexandria, Virginia, brought the patent infringement claims against Xenogenic Development LLC through the ITC's Section 337 process. Section 337 provides a mechanism for patent holders to seek exclusion orders against imported products that allegedly infringe U.S. patents.
The ITC investigation, designated as Investigation No. 337-TA-1391, resulted in the Administrative Law Judge granting summary determination in favor of the accused party. The ALJ found no infringement of either the '474 Patent or the '546 Patent, and consequently no violation of Section 337.
Following the ALJ's determination, the full Commission reviewed the decision and affirmed the finding of no infringement. This prompted Sandstrom's appeal to the Federal Circuit, which has exclusive jurisdiction over appeals from ITC patent decisions under 28 U.S.C. § 1295(a)(6).
The Federal Circuit panel, consisting of Circuit Judges Reyna, Wallach, and Hughes, issued a brief per curiam opinion written by Judge Wallach. The court's analysis focused on the technical aspects of the accused optical networking devices and how they related to the claims of Sandstrom's patents.
Optical line termination devices serve as crucial infrastructure components in fiber optic networks. These devices enable network service providers to efficiently manage and distribute optical signals to multiple end users. The technology involves splitting a single incoming optical signal into multiple output signals, as well as multiplexing capabilities that allow for bidirectional communication over fiber optic cables.
The patents at issue, filed several years apart, both relate to improvements in optical networking technology. The '474 Patent, numbered 10,567,474, and the '546 Patent, numbered 10,848,546, represent Sandstrom's claimed innovations in this field.
Xenogenic Development LLC, the accused infringer, was represented by attorneys from Sterne Kessler Goldstein & Fox PLLC, including John Christopher Rozendaal, John Hylton, and Michael E. Joffre. The company intervened in the proceedings to defend against the infringement allegations.
The ITC was represented by its Office of the General Counsel, with attorneys Jonathan Link, Michelle W. Klancnik, and Margaret D. MacDonald appearing for the Commission.
The Federal Circuit's decision to issue a nonprecedential opinion means the ruling will have limited value as legal precedent in future cases. Nonprecedential decisions typically involve straightforward applications of existing law or fact-specific determinations that are unlikely to provide broader guidance for similar disputes.
This case illustrates the challenges faced by pro se litigants in complex patent disputes, particularly in the specialized realm of ITC Section 337 proceedings. The Section 337 process requires detailed technical and legal analysis of patent claims, claim construction, and infringement theories.
The optical networking industry continues to face numerous patent disputes as companies compete to develop more efficient and cost-effective solutions for fiber optic communications. These technologies are essential for supporting increasing bandwidth demands in telecommunications networks.
For Sandstrom, the adverse Federal Circuit ruling represents the final resolution of his patent infringement claims against the accused optical networking devices. The affirmance of the ITC's no-infringement determination means no exclusion order will issue against the importation of the accused products.
The decision underscores the importance of thorough claim construction and infringement analysis in patent cases, particularly those involving complex technical subject matter. The ALJ's grant of summary determination suggests the evidence strongly favored the accused infringer's non-infringement position.
While this specific case may not create binding precedent, it adds to the body of Federal Circuit jurisprudence regarding optical networking patents and Section 337 proceedings. The outcome may influence how similar disputes are approached and resolved in future ITC investigations involving comparable technologies.