Goss v. MAN Roland

2007 DNH 029
CourtDistrict Court, D. New Hampshire
DecidedMarch 12, 2007
DocketCivil No. 03-cv-513-SM. Opinion No. 2006 DNH 088
StatusPublished

This text of 2007 DNH 029 (Goss v. MAN Roland) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Goss v. MAN Roland, 2007 DNH 029 (D.N.H. 2007).

Opinion

Goss v . MAN Roland 03-CV-513-SM 03/12/07 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Goss International Americas, Inc., Plaintiff

v.

MAN Roland, Inc. and MAN Roland Druckmaschinen AG, Defendants Civil N o . 03-cv-513-SM Opinion N o . 2007 DNH 029 MAN Roland, Inc. and MAN Roland Druckmaschinen AG Counterclaim Plaintiffs

v. Goss International Americas, Inc. and Heidelberger Druckmaschinen AG, Counterclaim Defendants

O R D E R

In a prior order (document n o . 1 0 1 ) , the court dismissed

Count 5 of MAN Roland’s counterclaim against Heidelberger, to the

extent it relates to the ‘251 patent. A subsequent order

(document n o . 410) granted summary judgment in Heidelberger’s

favor on the Walker Process claims in Count 5 , as they relate to

the ‘734 and ‘100 patents. All that remains of Count 5 is the

sham litigation and Walker Process claim to the extent they

relate to the ‘587 application. Heidelberger has filed a motion for summary judgment,

arguing that both the sham litigation and Walker Process claims

fail because revival of the ‘587 application was immaterial to

prosecution of the ‘100 and ‘734 patents. MAN Roland objects by

what it terms a “preliminary objection,”1 that does not address

the materiality issue, and instead focuses on whether the ‘587

patent was improperly revived and who, within Heidelberger, was

authorized to make the decisions to abandon and later revive the

application.

The Legal Standard

Section 2 of the Sherman Antitrust Act makes it unlawful for

any person to “monopolize, or attempt to monopolize . . . any

part of the trade or commerce among the several States.”

15 U.S.C. § 2 ; see also 15 U.S.C. § 15(a) (granting a private

right of action to “any person who shall be injured in his

business or property by reason of anything forbidden in the

antitrust laws”). A successful monopolization claim under

section 2 requires actual monopoly power and a wrongful act

designed to enhance that power. Town of Norwood v . N.E. Power

1 MAN Roland has also asked the court for additional time to more fully respond to Heidelberger’s motion (document n o . 4 3 4 ) , asserting that it needs additional discovery on the issue of the ‘587 application. Because the court resolves the instant motion on independent grounds, however, the motion for additional time is moot.

2 Co., 202 F.3d 4 0 8 , 420-21 (1st Cir. 2000) (citing Otter Tail

Power C o . v . United States, 410 U.S. 366, 377 (1973); United

States v . Grinnell Corp., 384 U.S. 563, 570-71 (1966)). A

successful attempted monopolization claim under section 2

requires anticompetitive conduct, a specific intent to

monopolize, and a dangerous probability of success. Spectrum

Sports, Inc. v . McQuillan, 506 U.S. 4 4 7 , 454-56 (1993).

Walker Process claims form a subset of section 2 claims in

which the allegedly anticompetitive conduct is the enforcement of

a fraudulently procured patent. Walker Process Equip., Inc. v .

Food Mach. & Chem. Corp., 382 U.S. 1 7 2 , 177 (1965). To establish

a claim for Walker Process fraud, the antitrust plaintiff must

prove, inter alia, that the patentee “obtained the patent by

knowingly and willfully misrepresenting facts to the [PTO],” id.,

and that the party enforcing the patent was aware of the fraud at

the time of enforcement. Nobelpharma AB v . Implant Innovations,

Inc., 141 F.3d 1059, 1069 (Fed. Cir. 1998) (citation omitted).

Moreover,

a finding of Walker Process fraud . . . must be based on independent and clear evidence of deceptive intent together with a clear showing of reliance, i.e., that the patent would not have issued but for the misrepresentation or omission.

Id. at 1071.

3 Sham litigation claims form another subset of section 2

claims, in which the allegedly anticompetitive conduct is the

enforcement of a patent through litigation, with knowledge that

the patent is invalid or not infringed. C.R. Bard, Inc. v . M3

Sys., Inc., 157 F.3d 1340, 1368 (Fed. Cir. 1998). To establish a

claim for sham litigation, the antitrust plaintiff must prove,

inter alia, that the challenged lawsuit is objectively baseless

and subjectively motivated “to interfere directly with the

business relationships of a competitor.” Prof’l Real Estate

Investors v . Columbia Pictures Indus., Inc., 508 U.S. 4 9 , 60-61

(1993) (quoting E . R.R. Presidents Conf. v . Noerr Motor Freight,

Inc., 365 U.S. 1 2 7 , 144 (1961)) (emphasis added in P R E ) . A

lawsuit is objectively baseless if “no reasonable litigant could

realistically expect success on the merits.” PRE, 508 U.S. at

60. A patent infringement suit is objectively baseless when the

infringement plaintiff knows that the patent is invalid or not

infringed. See C.R. Bard, 157 F.3d at 1368.

Discussion

Heidelberger argues that because the ‘587 application was

immaterial to the validity of the ‘100 and ‘734 patents, MAN

Roland’s claims of Walker Process fraud and sham litigation must

4 fail.2 In essence, Heidelberger asserts that even if it had

engaged in inequitable conduct related to the ‘587 application,

such conduct would be irrelevant to this case, because the ‘587

application is unrelated to the ‘100 and ‘734 patents.3

MAN Roland does not address the materiality issue in its

objection, thereby conceding the point.4 Indeed, the record

reveals that both the ‘100 and ‘734 patents can trace their

ancestry back through continuations dated prior to the

abandonment and subsequent revival of the ‘587 application. So,

it cannot be said that Heidelberger knew or should have known

that the ‘100 and ‘734 patents were invalid based upon alleged

inequitable conduct related to the ‘587 application, thereby

2 As discussed above, sham litigation claims may be based upon any objectively baseless action, including situations where the patent infringement plaintiff knows that the patent it seeks to enforce is invalid or not infringed. Here, as Heidelberger notes, MAN Roland has limited its sham litigation claim to allegations of inequitable conduct in the prosecution of the ‘587 patent, a premise to which MAN Roland does not object. See Countercl. Def.’s Mot. Summ. J. (document n o . 425) 24 n . 2 0 . 3 Heidelberger also argues, alternatively, that even if the ‘587 application is germane to the patents in suit, it is liable on neither the Walker Process nor sham litigation claims because its revival of the ‘587 application was proper. Because the motion can be resolved on the materiality issue alone, the court need not consider the alleged inequitable conduct in prosecuting the ‘587 application. 4 See L.R.

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Related

Fairfax Family Fund, Inc. v. California
382 U.S. 1 (Supreme Court, 1965)
United States v. Grinnell Corp.
384 U.S. 563 (Supreme Court, 1966)
Otter Tail Power Co. v. United States
410 U.S. 366 (Supreme Court, 1973)
Nobelpharma Ab v. Implant Innovations, Inc.
141 F.3d 1059 (Federal Circuit, 1998)
C.R. Bard, Inc. v. M3 Systems, Inc.
157 F.3d 1340 (Federal Circuit, 1998)
United States v. Ronald Woodrum
202 F.3d 1 (First Circuit, 2000)

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