Richards Layton & Finger
 

Senior Judge Robinson Denies Motions for Relief from Judgment

May 3, 2017

In Cloud Satchel LLC v. Amazon.com, Inc., C.A. No. 13-941-SLR and 13-942-SLR (D. Del. Mar. 30, 2017), Senior Judge Robinson denied a motion for relief from judgment filed by Cloud Satchel, LLC (“Cloud Satchel”) in these related cases. The Court had earlier ruled on summary judgment that the subject matter of the patents-in-suit was patent ineligible under Section 101, a ruling affirmed by the Federal Circuit.

Here, Cloud Satchel returned to the district court to move for relief from that judgment, arguing that subsequent Federal Circuit decisions called the basis for the judgment into question. Judge Robinson disagreed, finding that the Federal Circuit had affirmed the Court’s grant of summary judgment, and that the decisions cited by Cloud Satchel were neither en banc nor recognized to have changed the Section 101 framework in any appreciable manner. Instead, the Court stated that the cases cited by Cloud Satchel “simply reflect the reality that different panels may describe, interpret and/or apply existing precedent different in light of different facts.” The invalidation of the patents by the Federal Circuit was not an extreme or unexpected hardship under Fed. R. Civ. P. 60, and thus Judge Robinson denied the motion.

Key Points: Although Senior Judge Robinson noted that Section 101 jurisprudence “has been an evolving one,” the Court found that the plaintiff had failed to satisfy the high standard to alter or amend a judgment under Fed. R. Civ. P. 60. Seeking to have judgments overturned in light of new Federal Circuit precedent may require more than an arguably contradictory panel decision—instead, an en banc determination or decision of similar weight that changes the legal framework in a material way to the Court’s original analysis appears necessary.