Judge Robinson Denies Motion for Reconsideration of Prior Decision Granting Motion for Summary Judgment of “No Invalidity”
In Intermec Technologies Corp. v. Palm Inc., C.A. No. 07-272-SLR, Judge Robinson denied the plaintiff’s motion for reconsideration of a prior decision granting in part defendant’s motion for summary judgment. Id. at 11. Regarding the prior decision at issue, the defendant filed a motion for summary judgment of no invalidity and infringement of two patents-in-suit. Id. at 2. Conversely, the plaintiff filed a corresponding cross-motion for summary judgment of noninfringement and invalidity of the same. Id. at 2. In deciding the parties’ competing motions for summary judgment, on the issue of invalidity, the Court ruled in favor of the defendant. Id. at 1-2. In its summary judgment decision, the Court rejected the plaintiff’s anticipation, indefiniteness, non-enablement and lack of written description arguments and held that the asserted claims of the patents-in-suit were not invalid. Id. at 2-3. As a result, the plaintiff subsequently moved for reconsideration of that decision, arguing that, among other things, it was “necessary to ‘correct errors of law and fact and to prevent manifest injustice,’” and that the Court “did not apply the proper standard . . . in granting [defendant] summary judgment.” Id. at 4. The Court, however, denied the plaintiff’s motion for reconsideration, finding that the motion was without merit. In denying the motion, the Court noted that the plaintiff: (1) did not point to “a change in the controlling law or any newly discovered evidence”; (2) had not shown “a need to correct a clear error of law or prevent manifest injustice”; and (3) had not “demonstrated that the court patently misunderstood a party, . . . made a decision outside the adversarial issues presented to the court by the parties, or . . . made an error of apprehension.” Id. at 11. The Court further noted that the plaintiff’s motion for reconsideration sought to only reargue the same issues and evidence that were before the Court in the prior summary judgment decision, and that the plaintiff’s “chief complaint” was essentially that the Court did not weigh the facts of record as plaintiff would have wanted, and, as such, is “insufficient to meet the motion for reconsideration standard.” Id. at 11. This decision further exemplifies the point that the standard for obtaining relief on a motion for reconsideration is, indeed, “difficult for a plaintiff [or defendant] to meet.” Id. at 3.