Client Alerts & Newsletters

Adverse Economic Interest Not Sufficient To Confer Declaratory Judgment Jurisdiction

March 20, 2006

In Microchip Technology Inc. v. Chamberlain Group, Inc. (No. 05-1339; March 15, 2006), the Federal Circuit vacates the district court's grant of summary judgment in favor of Microchip and remands with instructions to dismiss the action. Chamberlain sued several of Microchip's customers for patent infringement despite having entered into a settlement pursuant to which Chamberlain agreed not to bring suit against Microchip for patent infringement. Microchip filed a complaint with the district court seeking a declaration that the settlement between Microchip and Chamberlain precludes Chamberlain from enforcing the subject patents against Microchip's customers under the doctrine of patent exhaustion.

The Federal Circuit finds that the district court lacked jurisdiction under the Declaratory Judgment Act since no “actual controversy” exists, as required under the Act. An “actual controversy” exists, says the Federal Circuit panel, where there is a “reasonable apprehension” that a party will face a patent infringement suit. Without an underlying legal cause of action, an adverse economic interest is not considered to be a legally cognizable interest sufficient to confer declaratory judgment jurisdiction.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

View Desktop Site | Mobile Sitemap |

Contact | Subscribe | Terms of Use | Privacy Statement | Alumni

© Crowell & Moring LLP 2022
Attorney advertising - prior results do not guarantee a similar outcome.