Medinol v. Cordis is a nonprecedential case decided on June, 12, 2020, on appeal from the Southern District of New York. After dismissing Plaintiff Medinol’s patent infringement claim as barred by laches, the district court denied Medinol Rule 60(b)(6) relief from the judgment. Medinol did not appeal the original judgment of dismissal. The Supreme Court then held in SCA Hygiene v. First Quality that laches is no longer a valid defense to bar patent damages within the statutory period, and the Federal Circuit vacated the denial of Rule 60(b)(6) relief and remanded. On remand, the district court denied Medinol’s renewed Rule 60(b)(6) motion to set aside the laches dismissal, “finding that Medinol failed to show the requisite extraordinary circumstances.” Medinol appealed.
The Federal Circuit affirmed the decision denying Rule 60(b)(6) relief.
Rule 60(b)(6) allows a district court to “relieve a party . . . from a final judgment, order, or proceeding” for “any . . . reason that justifies relief.” Medinol argued that relief from the judgment is warranted because “of the nature and magnitude of the [SCA Hygiene] change of law regarding the availability of a laches defense, and because it would work an undue hardship and injustice for Medinol to be denied the opportunity to have its patent infringement claims tried on the merits based on the initial ‘ultra vires’ district court judgment of dismissal.”
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The district court did not abuse its discretion or commit legal error. “There is no doubt that the Supreme Court… in [SCA Hygiene] dramatically changed the legal landscape for statutory infringement actions.” “But the district court found those factors outweighed by Medinol’s decision not to appeal and the absence of extraordinary prejudice or undue hardship.” “Nor did the district court violate SCA Hygiene by factoring the timing of Medinol’s suit into its undue hardship analysis.”
The district court “weighed Medinol’s decision not to appeal along with the other asserted factors in reaching its conclusion that extraordinary circumstances were not present.” Medinol argued that, “during the time period for taking an appeal, it had no reason to suspect that [the Federal Circuit’s] long-standing en banc decision endorsing laches as a defense to patent infringement… might soon be overturned.” Even before the district court’s laches judgment was rendered, “Medinol recognized the potential significance of the [Petrella v. Metro-Goldwyn-Mayer] laches-copyright infringement case that was being argued at the Supreme Court during the district court’s laches-patent infringement bench trial.” “That Medinol freely and voluntarily made the decision not to appeal, despite this awareness, can properly be viewed as a lack of diligence mitigating the claimed extraordinary nature of the case.”