SYNGENTA CROP PROTECTION, LLC v. WILLOWOOD, LLC
- Dec 18 2019 |
- Category: CAFC Updates
Syngenta sued Willowood for copyright infringement and patent infringement, asserting four patents directed to a fungicide compound and its manufacturing processes. Prior to trial, the district court dismissed the copyright infringement claims, determining them to be precluded by the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). Syngenta appeals, inter alia, the district court’s dismissal of its copyright claims, the district court’s conclusion that § 271(g) requires every step of a claimed process to be performed by or attributable to a single entity, the jury’s verdict that Willowood did not infringe the ’138 patent even with the single entity requirement imposed on § 271(g). The CAFC concludes that the district court did not provide an adequate analysis of the potential conflict between FIFRA and the Copyright Act for the CAFC to determine whether such a conflict truly exists, and urges the district court on remand to discern whether the Copyright Act, as interpreted under existing copyright doctrines, would prohibit Willowood’s use of any portion of Syngenta’s label, and if so, revisit the question of whether and to what extent FIFRA precludes Syngenta’s copyright claims for any part of its pesticide labels. The CAFC also concludes that the district court erred by imposing a single-entity requirement on the performance of a patented process under § 271(g), holding that § 271(g) does not require a single entity to perform all of the steps of a patented process for infringement liability to arise from the importation into the United States or offer to sell, sale, or use within the United States of a product made by a process patented in the United States. Accordingly, the CAFC affirms-in-part, reverses-in-part, vacates-in-part, and remands.