The U.S. Court of Appeals for the Federal Circuit issued a nonprecedential decision Thursday affirming a district court judgment that found claims 1 and 6 of U.S. Patent No. 6,821,540 invalid as indefinite under 35 U.S.C. § 112 in patent litigation between J.R. Simplot Co. and McCain Foods USA, Inc. and McCain Foods Ltd. The ruling represents the conclusion of a complex legal battle between two major players in the food processing industry.
The Federal Circuit panel, consisting of Circuit Judges Dyk, Hughes, and Stoll, issued a brief per curiam opinion affirming the lower court's invalidity determination. Under 35 U.S.C. § 112, patent claims must be sufficiently definite to inform those skilled in the art about the scope of the invention with reasonable certainty. The appeals court affirmed that the asserted claims 1 and 6 failed to meet this definiteness requirement.
The litigation originated in the U.S. District Court for the District of Idaho, where two separate cases were consolidated under the jurisdiction of Judge David C. Nye. The first case, filed in 2016, involved J.R. Simplot Co. as plaintiff against McCain Foods USA, Inc. A second case filed in 2017 saw McCain Foods Ltd. as plaintiff against J.R. Simplot Co., creating a complex web of cross-claims and counterclaims.
Adding further complexity to the litigation, J.R. Simplot Co. brought third-party defendants into the dispute, including German company Elea. The consolidated cases involved multiple patent-related claims and counterclaims between the food processing companies.
The Federal Circuit's affirmance of the invalidity finding means that the specific patent claims at issue cannot be enforced against the McCain Foods entities, resolving this aspect of the dispute in favor of the defendants on those particular claims.
