Anza Technology, Inc. v. Mushkin, Inc., No. 19-1045 (Fed. Cir. 2019)
Annotate this CaseIn September 2017, Anza alleged that Mushkin had infringed its 927 patent, entitled “Flip Chip Bonding Tool and Ball Placement Capillary,” which relates to “dissipative and insulative ceramic flip chip bonding tools and capillaries for ball placement for bonding electrical connections.” After Mushkin was severed from another defendant and the case was transferred, the parties engaged in mediation. Anza conceded that its claims were no longer viable and was permitted to file an amended complaint in June 2018; Anza removed the infringement allegations regarding the 927 patent and alleged infringement of the 479 and 864 patents under 35 U.S.C. 271(g). Anza also omitted 10 of the 16 products that had originally been accused and added two new products. The district court dismissed, finding that Anza’s claim of damages for patent infringement was barred by the six-year statute of limitations, 35 U.S.C. 286 because the claims in Anza’s second amended complaint did not relate back to the date of Anza’s original complaint. The Federal Circuit vacated, finding the district court’s application of the relation-back doctrine overly restrictive. Claims in the second amended complaint that relate to the six originally accused products relate back to the original filing date and are not barred. For the products that were added in the second amended complaint, the district court must determine whether the allegations regarding those products are sufficiently similar that they should relate back to the filing date of the original complaint.
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