Sansone v. United States Patent and Trademark Office

CourtDistrict Court, E.D. Virginia
DecidedMarch 4, 2025
Docket1:24-cv-00019
StatusUnknown

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

Bluebook
Sansone v. United States Patent and Trademark Office, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division STANLEY A. SANSONE, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:24-cv-19 (RDA/WEF) ) UNITED STATES PATENT AND ) TRADEMARK OFFICE, et al., ) ) Defendants. ) MEMORANDUM OPINION AND ORDER This matter comes before the Court on Defendants’! Motion to Dismiss (Dkt. 16). This Court has dispensed with oral argument as it would not aid in the decisional process. See Fed. R. Civ. P. 78(b); Local Civil Rule 7(J). This matter has been fully briefed and is now ripe for disposition. Considering the Motion together with Defendants’ Memorandum in Support (Dkt. 17), Plaintiff's Opposition (Dkt. 19), Defendants’ Reply (Dkt. 21), Plaintiff's Sur-Reply (Dkt. 21); and Plaintiff's Attachment to his Sur-Reply (Dkt. 22), this Court GRANTS the Motion for the reasons that follow.

' Defendants here are the United States Patent and Trademark Office (“USPTO”) and Kathi Vidal, the Undersecretary of Commerce for Intellectual Property and Director of the USPTO (the “Director’). With the change in presidential administration, Coke Morgan Stewart is the current Acting Undersecretary of Commerce for Intellectual Property and Acting Director of the USPTO. See https://www.uspto. gov/about-us/organizational-offices/office-under-secretary-and-director (last visited February 28, 2025). Although Plaintiff does not specifically note that he intended to allege claims against the Director in her official capacity, the Court — like the Government — assumes that Plaintiff intended to name the Director in her official capacity as the Director was not personally served and there are no allegations regarding individual actions of the Director. Dkt. 17 at 5 n.4. ? Plaintiff also has pending before the Court a Motion for Summary Judgment (Dkt. 23), a Motion for Electronic Device Application (Dkt. 26), and a Letter Motion regarding Amendment (Dkt. 27). The Motion for Summary Judgment will be denied as premature. The Motion for Electronic Device Application will be denied as moot because there is no court proceeding for which such application is necessary. Finally, the Letter Motion will be denied as moot given the outcome of the Motion to Dismiss here.

I. BACKGROUND A. Factual Background? The essential thrust of the Amended Complaints is that Plaintiff Stanley A. Sansone challenges the USPTO’s rejection of U.S. Patent Application No. 16/255,511 (the “’511 Application”) in a final decision by the Patent Trial and Appeals Board (the “PTAB”). Dkt. 1 at 5; Dkt. 14; Dkt. 15. Plaintiff filed the 511 Application on January 23, 2019. Dkt. 15 at 27. The °511 Application described a “Wearable Thermal Device with Port” for therapeutic treatment to a part of the body. Dkt. 15 at 5; Dkt. 15-2 at 99.4 The patent examiner rejected the claims in the Application and Plaintiff appealed to the PTAB. Dkt. 15 at 5. The PTAB then affirmed the examiner’s rejection. See Ex parte Sansone, Appeal No. 2021-1334, 2021 WL 2982138 (PTAB July 13, 2021) (Sansone De After the PTAB issued its decision, Plaintiff submitted a Request for Continued Examination on September 9, 2021. Dkt. 15-2 at 97. The examiner issued a non-final rejection on October 4, 2021. Id. Plaintiff amended his application on January 3, 2022, and the examiner issued a final rejection of all claims on March 1, 2022. Jd. Plaintiff appealed this second final rejection to the PTAB, which

3 For purposes of considering the instant Motion to Dismiss, the Court accepts all facts contained within the Amended Complaints as true, as it must at the motion-to-dismiss stage. Ashcroft v. Iqbal, 556 U.S, 662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). As a matter of procedure, Defendants are correct that Plaintiff was permitted to amend his complaint once as of right and that Plaintiff subsequently required leave of Court. Plaintiff here has twice amended his Complaint. Dkts. 14, 15. In deference to Plaintiff's pro se status, and because Defendants address the allegations in both Amended Complaints and because it makes no difference to the outcome here, the Court will likewise look to and rely on both filings as they are substantially similar. 4 Docket entry 15-2 is a collection of documents. Accordingly, page references to this docket entry refer to the CM/ECF assigned page numbers rather than any page numbers original to the documents. > The PTAB’s decision is properly subject to judicial notice. See Doe v. Old Dominion Univ., 2017 WL 11509351, at *5, (E.D. Va. June 26, 2017) (“The court may take judicial notice of public court records and parties’ admissions even if they are attached only to the motion to dismiss.”) (citing Zak v. Chelsea Therapeutics Int’l, Ltd., 780 F.3d 597, 606-07 (4th Cir. 2015)); see also SC Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 1363 n.39 (3d ed. 2004).

affirmed the examiner’s decision on July 19, 2023. See Ex parte Sansone, Appeal No. 2023-001331, 2023 WL 4677708 (PTAB July 19, 2023) (Sansone ID) Plaintiff asserts that the USPTO “deprived Sansone of a civil right to fair and lawful patent prosecution and trial.” Dkt. 15 at 14. Plaintiff asserts that Defendants violated the “civil rights” protections of 42 U.S.C. §§ 1983 and 1985 and 18 U.S.C. § 242 as well as 18 U.S.C. § 1519 and 28 U.S.C. § 2675. Dkt. 14 at 1. Plaintiff also alleges claims pursuant to the Federal Tort Claims Act (“FTCA”) and the Fifth Amendment to and the Patent Clause of the United States Constitution. Dkt. 15 at 22-24. B. Procedural Background On January 4, 2024, Plaintiff filed his original Complaint. Dkt. 1. On April 17, 2024, Plaintiff filed his first “Amended Pleading, Opening Brief.” Dkt. 14. On May 16, 2024, Plaintiff filed his second “Opening Brief, Amended Pleading with Supporting Documents & Footnote References.” Dkt. 15. On June 17, 2024, Defendants filed their Motion to Dismiss. Dkt. 16. On July 8, 2024, Plaintiff filed his Response. Dkt. 19. On July 16, 2024, Defendants filed their Reply. Dkt. 20. On July 29, 2024, Plaintiff filed a Sur-Reply. Dkt. 20. On August 1, 2024, Plaintiff filed an attachment to his Sur- Reply. Dkt. 22. On August 6, 2024, Plaintiff filed his Motion for Summary Judgment. Dkt. 23. On August 20, 2024, Defendants filed their Opposition. Dkt. 25. On September 3, 2024, Plaintiff filed a Motion for Electronic Device Application. Dkt. 26. On September 17, 2024, Plaintiff filed a one-page: “Letter to the Court, Amended Complaint.” Dkt. 27. I. STANDARD OF REVIEW A. Rule 12(b)(1) Federal Rule of Civil Procedure 12(b)(1) provides for dismissal when the Court lacks jurisdiction over the subject matter of the action. A district court must dismiss an action over which it

lacks subject-matter jurisdiction. Fed. R. Civ. P. 12(b)(1), (h)(3). In considering a Rule 12(b)(1) motion to dismiss, the burden is on the plaintiff to prove that subject-matter jurisdiction is proper. See United States v. Hays, 515 U.S. 737

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Sansone v. United States Patent and Trademark Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sansone-v-united-states-patent-and-trademark-office-vaed-2025.