Ropes & Gray LLP v. Jalbert

910 N.E.2d 330, 454 Mass. 407, 93 U.S.P.Q. 2d (BNA) 1146, 2009 Mass. LEXIS 421
CourtMassachusetts Supreme Judicial Court
DecidedJuly 28, 2009
StatusPublished
Cited by28 cases

This text of 910 N.E.2d 330 (Ropes & Gray LLP v. Jalbert) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ropes & Gray LLP v. Jalbert, 910 N.E.2d 330, 454 Mass. 407, 93 U.S.P.Q. 2d (BNA) 1146, 2009 Mass. LEXIS 421 (Mass. 2009).

Opinion

Spina, J.

We consider in the present case, as a matter of first impression, the scope of the Massachusetts attorney’s lien statute (lien statute), G. L. c. 221, § 50, vis-a-vis patent prosecution work. The United States Court of Appeals for the First Circuit has certified the following questions to this court, pursuant to S.J.C. Rule 1:03, as appearing in 382 Mass. 700 (1981)2:

“1. Does [G. L. c. 221, § 50,] grant a lien on patents [408]*408and patent applications to a Massachusetts attorney for patent prosecution work performed on behalf of a client?
“2. If [G. L. c. 221, § 50,] does grant a lien and the issued patents or patent applications are sold, does the attorney’s lien attach to the proceeds of the sale?”

In re Engage, Inc., 544 F.3d 50, 58 (1st Cir. 2008). We answer both of the certified questions in the affirmative.3

1. Background. We briefly summarize the facts as set forth in the opinion accompanying the certification order, supplemented by details provided in the underlying bankruptcy proceedings. See In re Engage, Inc., 544 F.3d at 51-52; In re Engage, Inc., 315 B.R. 208, 210-211 (Bankr. D. Mass. 2004), aff’d, 330 B.R. 5, 7-8 (D. Mass. 2005).

On June 19, 2003, Engage, Inc., an advertising software company, and certain of its affiliates (collectively, the debtors) filed petitions in the United States Bankruptcy Court for the District of Massachusetts for relief under Chapter 11 of the Bankruptcy Code. See 11 U.S.C. §§ 101 et seq. (2000). Ropes & Gray LLP (Ropes & Gray), which had provided legal services to the debtors from approximately June, 2002, through May, 2003, in connection with the prosecution of various patents, was scheduled as a creditor in the debtors’ bankruptcy. In a filing with the Bankruptcy Court, Ropes & Gray asserted that it was owed $108,737.11 for unpaid patent prosecution work performed before June 19, 2003, secured by an attorney’s lien under G. L. c. 221, § 50, on “(i) certain patents and patent prosecution actions of the Debtor and (ii) cash proceeds of a prepetition sale of other patents.” In addition, Ropes & Gray asserted an unsecured creditor’s claim for approximately $49,517.37, primarily for corporate licensing work performed in 2003.

The debtors, who had sold their patents and patent applica[409]*409tions in transactions before and after June 19, 2003,4 agreed to maintain a cash reserve of $108,737.11 from the sale proceeds, thereby providing Ropes & Gray with adequate protection in the event that pending litigation over the existence and validity of the asserted attorney’s lien was resolved in its favor, while also reserving the debtors’ rights to object to Ropes & Gray’s claims. On May 20, 2004, the Bankruptcy Court entered an order confirming the debtors’ second amended plan of liquidation under Chapter 11. Shortly thereafter, the debtors’ liquidating supervisor, Craig Jalbert, filed an objection to Ropes & Gray’s secured claim, contending, among other things, that G. L. c. 221, § 50, did not apply to patents and patent applications, and, therefore, Ropes & Gray was an unsecured creditor. The Bankruptcy Court agreed, sustaining the liquidating supervisor’s objection and concluding that the lien statute did not apply to patent prosecution work. See In re Engage, Inc., 315 B.R. at 210, 213-217.

Ropes & Gray appealed from the Bankruptcy Court’s order to the United States District Court for the District of Massachusetts. It also filed a motion requesting that the District Court certify various questions on the lien statute to this court. On September 1, 2005, the District Court affirmed the Bankruptcy Court, concluding that an attorney’s lien under G. L. c. 221, § 50, did not attach in favor of Ropes & Gray to the patents, the patent applications, or the proceeds from their resulting sales, based on Ropes & Gray’s representation of the debtors in patent prosecution proceedings before the United States Patent and Trademark Office (USPTO). See In re Engage, Inc., 330 B.R. at 5, 7, 14-21. The District Court also rejected Ropes & Gray’s request that it certify questions to this court, stating that the issue of the lien statute’s applicability to patent prosecution [410]*410work could be resolved by analyzing existing case law. See id. at 6 & n.l. The matter was returned to the Bankruptcy Court because its order was not yet “final” within the meaning of 28 U.S.C.A. § 158(d) (West 2006 & Supp. 2008).

On August 15,2007, Ropes & Gray and the liquidating supervisor filed a joint motion with the Bankruptcy Court, agreeing to liquidate Ropes & Gray’s claim. They also agreed that the liquidating supervisor would set aside $27,500, which Ropes & Gray would receive if ultimately it were found to have a secured claim. In its final order issued on September 10, 2007, the Bankruptcy Court approved this compromise and disallowed Ropes & Gray’s secured claim. Ropes & Gray appealed, and on December 28, 2007, the District Court affirmed this final order on the grounds set forth in its September 1, 2005, decision.

Ropes & Gray appealed to the United States Court of Appeals for the First Circuit and again requested that questions regarding the lien statute be certified to this court. Finding no controlling precedent on whether G. L. c. 221, § 50, applies to patent prosecution work, and, if so, whether the attorney’s lien attaches to proceeds from the sale of issued patents or patent applications, and concluding that this State law issue could be determinative of Ropes & Gray’s cause of action, the Court of Appeals certified the two questions now before us. See In re Engage, Inc., 544 F.3d at 52-58.

2. Nature of patent prosecution work. Before considering the specifics of the lien statute, we highlight a few pertinent details about the nature of patents and patent prosecution work. A patent confers on its owner the right to exclude others from making, using, offering for sale, or selling the patented invention. See 35 U.S.C. § 154(a)(1) (2006). See also 35 U.S.C. § 271 (2006) (action for infringement of patent). Fundamentally, a patent is a property right. See 35 U.S.C. § 261 (2006) (“patents shall have the attributes of personal property”); Connell v. Sears, Roebuck & Co., 722 F.2d 1542,1548 (Fed. Cir. 1983) (“the right to exclude recognized in a patent is but the essence of the concept of property”); Carl Schenck, A.G. v. Nortron Corp., 713 F.2d 782, 784 (Fed. Cir. 1983) (patent is exemplification of property right). This property interest, even at the patent application stage, is freely assignable. See 35 U.S.C. § 261

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Bluebook (online)
910 N.E.2d 330, 454 Mass. 407, 93 U.S.P.Q. 2d (BNA) 1146, 2009 Mass. LEXIS 421, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ropes-gray-llp-v-jalbert-mass-2009.