n a loss for Cellspin Soft, Inc., the U.S. Court of Appeals for the Federal Circuit (CAFC) issued two separate decisions today affirming a district court’s grant of summary judgment of noninfringement and denial of a motion for recusal in favor of Fitbit LLC and a number of other defendants. In one decision, the CAFC affirmed the district court’s grant of summary judgment of noninfringement of Cellspin’s U.S. Pat. No. 8,738,794 (the ’794 patent), U.S. Pat. No. 8,892,752 (the ’752 patent), and U.S. Pat. No. 9,749,847 (the ’847 patent). The patents are directed to issues with distributing multimedia content. In 2019, the Federal Circuit vacated the district court’s dismissal of the case under Rule12(b)(6) due to its determination that the patents were ineligible under Section 101, finding that the district court misconstrued precedent from both Aatrix Software, Inc. v. Green Shades Software, Inc., 882 F.3d 1121 (Fed. Cir. 2018) and Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018).
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