Raylon, LLC v. Complus Data Innovations, Inc., No. 11-1355 (Fed. Cir. 2012)
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Raylon’s patent, directed to a hand-held identification investigating and ticket issuing system is intended to provide an affordable system that reduces the amount of time a user spends identifying and issuing tickets and allows the user to maintain visual contact with the individual throughout the process. The system has a housing containing an input assembly for entering data, an elongated slot for receiving identification forms that have a magnetic tape, an elongated aperture for access to the housing’s interior, a transceiver assembly to communicate remotely with a computer, a printer assembly for printing tickets, and a display, pivotally mounted on the housing. Raylon alleged infringement by three defendants. The district court granted summary judgment in favor of the defendants, denied their motions for Rule 11 sanctions, and denied attorneys’ fees and costs under 35 U.S.C. 285, citing its Rule 11 decision. The Federal Circuit reversed as to Rule 11. The district court erroneously evaluated Raylon’s damages model and early settlements to determine whether it brought its suits in good faith or merely to obtain nuisance value settlements; it should have conducted an objective inquiry and “expressly rejected any inquiries into the motivation behind a filing.”
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