Inline Packaging, LLC v. Graphic Packaging International, LLC, No. 18-3167 (8th Cir. 2020)
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Inline filed suit against its competitor, Graphic, alleging antitrust and tortious interference claims related to the susceptor-packaging market.
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Graphic, holding that the district court did not err concluding that there was no genuine dispute of material fact regarding whether Graphic fraudulently procured patents on packaging concepts and designs through false claims of inventorship of the asserted patents and fraudulently concealed prior sales of drawing sample sleeves. In this case, Inline cannot establish that Graphic committed knowing and willful fraud and thus his monopolization claim under 15 U.S.C. 2 failed. Because Inline did not evidence fraud related to Graphic's procurement of the asserted patents and its prior sales of drawing sample sleeves 50019D/F, it has not established why the same set of facts and evidence would render Graphic's patent-infringement litigation objectively baseless. Therefore, the court affirmed the district court's dismissal of the sham-litigation claim.
The court affirmed the district court's dismissal of the discount-bundling claim because Inline failed to show that Graphic held sufficient monopoly or market power, and the district court adequately assessed the record and did not abuse its discretion in dismissing Inline's economic expert's untimely market opinion. Finally, the court held that the district court did not abuse its discretion in rejecting Inline's exclusive dealing claim and tortious interference claim.
Court Description: [Smith, Author, with Gruender and Benton, Circuit Judges] Civil case - Antitrust and Patents. In action alleging Graphic monopolized the susceptor-packaging market for frozen microwave foods by using anticompetitive conduct, including fraudulently procuring patents, making baseless litigation threats relating to the patents and using predatory-discount bundling, the district court did not err in granting Graphic's motion for summary judgment; the record did not establish Graphic fraudulently procured patents on packaging concepts and designs through false claims of ownership; because plaintiff failed to establish fraud with respect to the procurement of the patents, Graphic's patent-litigation could not be a sham or baseless; with respect to the bundling claim, plaintiff failed to show Graphic held sufficient monopoly or market power regarding the sale of paperboard packaging to survive summary judgment; the district court did not err in determining the complaint failed to allege an exclusive dealing claim; because plaintiff failed to establish that Graphic fraudulently procured its patents or that its patent-infringement suits were objectively baseless, plaintiff's tortious-interference claims cannot survive federal preemption.
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