SFA Sys., LLC v. Newegg, Inc., No. 14-1712 (Fed. Cir. 2015)
Annotate this CaseSFA’s patents relate to a computer sales system that includes multiple subsystems or components; each component corresponds to a different phase of the sales process. The patents disclose “an event manager” that detects “events” and automatically implements operation. SFA sued online retailers, including Newegg, alleging infringement. After other accused infringers settled, the district court held Markman hearings and rejected Newegg’s proposed constructions that limited the asserted claims to systems that assist a salesperson, or are used by a salesperson. Newegg also argued that claims were invalid as indefinite, because the system claims contained method step limitations, making it unclear when infringement occurs. The parties jointly sought extension of the case schedule. The court denied the motion as premature and denied summary judgment that the claims were indefinite. The next day, SFA moved to dismiss with prejudice and covenanted not to sue Newegg on the patents at issue. The court found that Newegg was the prevailing party and granted costs, but denied its 35 U.S.C. 285 motion for attorneys’ fees citing the Supreme Court’s standard in Octane (2014), finding that, “[e]ven under the new, lower standard for an exceptional case designation, Newegg has provided no evidence that this case ‘stands out from others with respect to the substantive strength of [SFA’s] litigating position.’” The Federal Circuit affirmed.
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