Morinville v. United States Patent and Trademark Office

CourtDistrict Court, District of Columbia
DecidedFebruary 26, 2020
DocketCivil Action No. 2019-1779
StatusPublished

This text of Morinville v. United States Patent and Trademark Office (Morinville v. United States Patent and Trademark Office) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morinville v. United States Patent and Trademark Office, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

PAUL MORINVILLE, et al., Plaintiffs v. Civil Action No. 19-1779 (CKK) UNITED STATES PATENT AND TRADEMARK OFFICE, Defendant

MEMORANDUM OPINION (February 26, 2020)

Plaintiffs, Paul Morinville, Gilbert Hyatt, and a class of similarly situated persons, bring

four claims against Defendant, the United States Patent and Trademark Office (“PTO”). These

claims all relate to a now-defunct program operated by Defendant called the “Sensitive

Application Warning System” (“SAWS”), which Plaintiffs claim was in violation of the Privacy

Act.

Before the Court is Defendant’s Motion to Dismiss. Defendant argues that Plaintiffs’

Privacy Act claims should be dismissed because the Privacy Act does not apply to either patent

application files or to the records which were kept under SAWS. Defendant further moves for

dismissal of Plaintiffs’ Declaratory Judgment Act claim, requesting that the Court declare that

SAWS violated the Privacy Act, because the Privacy Act precludes such relief. Finally,

Defendant moves to dismiss all claims by Plaintiff Morinville on the ground that he has not

alleged that his claims fall within the Privacy Act’s statute of limitations.

Upon consideration of the pleadings1, the relevant legal authorities, and the record for

purposes of this motion, the Court GRANTS IN PART AND DENIES WITHOUT PREJUDICE

1 The Court’s consideration has focused on the following documents:

1 IN PART Defendant’s Motion. The Court DENIES WIHOUT PREJUDICE IN PART

Defendant’s motion based on the conclusion that Plaintiffs have alleged facts sufficient to create

an inference that the records kept by SAWS are covered under the Privacy Act and that

Defendant’s practices through SAWS violated certain provisions of the Privacy Act. As to

Plaintiffs’ request for declaratory relief, at this time, it is not clear to the Court that Plaintiffs’

claim under the Declaratory Judgment Act is barred by the Privacy Act. Additionally, the Court

finds that it is not apparent from the face of the Amended Complaint that Plaintiff Morinville’s

claims are untimely. However, the Court also GRANTS IN PART Defendant’s motion and

DISMISSES Plaintiffs’ Count 4 Privacy Act claim for the prohibited collection of information

because Plaintiffs failed to allege a connection between Defendant’s method of information

gathering and any adverse determinations.

I. BACKGROUND

The Privacy Act requires that agencies, such as Defendant, “maintain all records which

are used by the agency in making any determination about any individual with such accuracy,

relevance, timeliness, and completeness as is reasonably necessary to assure fairness to the

individual in the determination[.]” Am. Compl., ECF No. 10, ¶ 8 (quoting 5 U.S.C. §

552a(e)(5)). The Privacy Act also requires that agencies “maintain no record describing how any

individual exercises rights guaranteed by the First Amendment unless expressly authorized by

• Def.’s Mem. in Support of Def.’s Mot. to Dismiss Pls.’ First Am. Compl. (“Def.’s Mot.”), ECF No. 12; • Pls.’ Res. in Opp’n to Def.’s Mot. to Dismiss (“Pls.’ Opp’n”), ECF No. 14; and • Def.’s Reply Brief in Support of Def.’s Mot. to Dismiss Pls.’ First Am. Compl. (“Def.’s Reply”), ECF No. 15. In an exercise of its discretion, the Court finds that holding oral argument in this action would not be of assistance in rendering a decision. See LCvR 7(f).

2 statute or by the individual about whom the record is maintained or unless pertinent to and within

the scope of an authorized law enforcement activity[.]” Id. at ¶ 9 (quoting 5 U.S.C. § 552a(e)(7)).

Finally, as is relevant here, the Privacy Act requires that agencies “collect information to the

greatest extent practicable directly from the subject individual when the information may result

in adverse determinations about an individual’s rights, benefits, and privileges under Federal

programs[.]” Id. at ¶ 10 (quoting 5 U.S.C. § 552a(e)(2)).

Based on these provisions of the Privacy Act, Plaintiffs bring claims against Defendant

stemming from a program called SAWS. The SAWS program “blocked issuance of patent

applications identified as ‘sensitive’ by PTO personnel.” Id. at ¶ 1. According to Plaintiffs, patent

applicants were not alerted that their patent applications had been flagged nor were they provided

the factual bases for the flagging which was included in the SAWS report. Without such

information, Plaintiffs were prevented from challenging the specific basis of the flagging. Id.

Plaintiffs further contend that once an application was flagged, a patent could not issue. Id. For

various reasons, Plaintiffs contend that Defendant’s operation of the SAWS program violated

provisions of the Privacy Act.

According to Plaintiffs, beginning in approximately 1994, Defendant began operating the

SAWS program; however, the program was not disclosed to the public until approximately 2014.

Id. at ¶¶ 18-19. Under SAWS, PTO personnel flagged sensitive applications. Id. at ¶ 20. Plaintiffs

allege that patent applications could be flagged for a variety of reasons relating to the proposed

invention including the possibility for publicity, old effective filing dates with broad-scope

patents, or objectionable or derogatory subject matter. Plaintiffs allege that the applications could

also be flagged based on the identity of the patent applicant. Id. at ¶¶ 22-26. Once an application

was flagged, PTO personnel would prepare a SAWS report, identifying the factual basis for the

3 flag. Such information could include financial information, politically-charged subject matter, or

legal or ethical objections to the application. Id. at ¶ 32. In order to prepare the reports, PTO

personnel performed internet searches about the invention, the inventors, and the assignor or the

assignee. Id. at ¶ 33.

Plaintiffs further allege that once an application received a SAWS flag, the patent

application could not be granted until the flag was removed, even if the application otherwise

complied with the statutory criteria for patentability. Id. at ¶¶ 27, 36. Plaintiffs contend that

Defendant had no defined process to remove a SAWS flag from an application. Id. at ¶ 37. As

such, in addition to the procedural burdens, delay, and increased scrutiny, Plaintiffs claim that a

SAWS flag resulted in a constructive denial of a patent application. Id. at ¶ 38.

Despite the significant effect of a SAWS flag, Plaintiffs allege that patent applicants were

not notified that a SAWS flag had been placed on their applications nor were they provided the

SAWS reports. Id. at ¶¶ 42-43. Additionally, SAWS material was not included in the patent

application file accessible to patent applicants. Id. at ¶ 44. Because they were unaware of the

flags, applicants could not challenge the specific factual basis for their SAWS status or their

constructive denials. Additionally, Plaintiffs claim that in administrative appeals involving

SAWS-flagged applications, the appeals board was provided with the SAWS information,

including the SAWS report. Id. at ¶ 46. Plaintiffs contend that applicants did not know that the

appeals board had been provided the SAWS material. Id. at ¶ 48.

As to the named Plaintiffs, Mr.

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