On February 25, 2026, a panel of the Seventh Circuit held oral argument in the case of Kangol LLC v. Hangzhou Chuanyue Silk Import & Export Co., Ltd., No. 25-2205. The appeal arises out of an unsuccessful attempt to void a default judgment against a Chinese entity...
Client-Centered Intellectual Property Solutions
Year: 2026
Federal Circuit Clarifies When Non-Infringing Products Can Form Part of a Royalty Base
On March 6, 2026, the Federal Circuit issued a precedential opinion in the case of Exafer Ltd. v. Microsoft Corporation (No. 24-2296) reversing a district court’s exclusion of the patent owner’s damages expert’s opinion. A patent owner who successfully obtains a...
Federal Circuit Confirms Broad USPTO Director Discretion In IPR Institution Decisions
Case Overview On February 13, 2026, the United States Court of Appeals for the Federal Circuit issued its precedential decision in Apple Inc. v. Squires, Case No. 2024-1864 (Fed. Cir. Feb. 13, 2026), affirming the Northern District of California’s rejection of an...
Seventh Circuit Poised to Rule on Alternative Service by Email on Chinese “Schedule A” Defendants (Maybe)
On February 25, 2026, a panel of the Seventh Circuit held oral argument in the case of Kangol LLC v. Hangzhou Chuanyue Silk Import & Export Co., Ltd., No. 25-2205. The appeal arises out of an unsuccessful attempt to void a default judgment against a Chinese entity...
Result-Oriented Software Claims Fall Short as Federal Circuit Demands Technological Improvement
Case Overview On January 22, 2026, the United States Court of Appeals for the Federal Circuit affirmed the Rule 12 dismissal of a patent infringement action brought by US Patent No. 7,679,637 LLC against Google LLC, holding that the asserted claims were directed to...
Second Circuit Limits Alternative Service by Email on Chinese “Schedule A” Defendants in Case of First Impression
Let’s begin with the bottom line: “In sum, we conclude that email service on the Chinese defendants is prohibited by the Hague Service Convention, and thus improper under Rule 4(f)(3).” Smart Study Co., LTD. v. Acuteye-US, No. 24-313, slip op. at 19 (2nd Cir. December...



