In a recent memorandum order, Judge Richard G. Andrews denied a motion for reconsideration of a summary judgment of non-infringement ruling. Robocast, Inc. v. Apple Inc., C.A. No. 11-235-RGA (D. Del. June 11, 2014). The plaintiff argued that the Court made a “factual oversight” in rendering its decision, but Judge Andrews disagreed, explaining, “[t]he entirety of the argument is one sentence buried in a footnote. . . . I do not agree that a conclusory statement buried in a footnote is sufficient to constitute an ‘overlooked argument.’” Regardless, the Court found that summary judgment would have been appropriate even had the argument been properly raised, so the motion for reconsideration was denied.