Stoel Rives Prevails for SnapPower in Dispute Over Jurisdiction for Hearing Patent Infringement Complaint

PORTLAND, Ore.—Stoel Rives is pleased to have represented SnapRays, LLC (dba SnapPower) in reversing the dismissal by a district court of a declaratory judgment patent infringement case filed by SnapPower, which the company had sought to have adjudicated in its home state of Utah.

The dispute originated when Lighting Defense Group LLC (LDG), a manufacturer of electrical faceplates, used the neutral Amazon Patent Evaluation Express (APEX) program to file a patent infringement complaint against SnapPower’s product listings on Amazon.com. Presented with options under APEX, SnapPower chose to seek a declaratory judgment of non-infringement in federal court in Utah. LDG moved to dismiss the case based on a lack of personal jurisdiction on the grounds that the correct venue to decide the case was Washington, where the APEX program is administered.

The district court dismissed the case, citing a lack of personal jurisdiction over LDG, as the complaint was deemed not sufficiently connected to Utah. However, the U.S. Court of Appeals for the Federal Circuit reversed this decision, establishing that the APEX complaint was purposefully directed at Utah, where SnapPower is based, and thus targeted a Utah resident and Utah commerce. 

This Federal Circuit decision underscores the notion that patent owners engaging in enforcement actions through neutral e-commerce platforms can be subject to personal jurisdiction in the locations where alleged infringers reside. This ruling is a crucial development for e-commerce entities facing cross-jurisdictional legal challenges and aligns the Federal Circuit’s personal jurisdiction jurisprudence with its sister circuits on matters of extrajudicial intellectual property enforcement activities. Additionally, it harmonizes the application of this law across the disciplines of patent, copyright, and trademark litigation, thereby establishing consistent legal standards across these key areas of intellectual property protection.

The Stoel Rives team that represented SnapPower was led by Elliott Williams, who presented arguments before the U.S. District Court and Federal Circuit, and included Nathan Brunette, Josh Gigger, and Brian Park.   

For more information, see a Law360 article.