Samsung Electronics Co. Ltd. v Apple, Inc.

Samsung sought review of the federal Circuit’s decision upholding a large patent infringement verdict. The Court unanimously reversed and remanded. It held that under the plain language of 35 USC 289, “article of manufacture”, which identifies what receives patent protection and the selling of which triggers liability, means a thing made by hand or machine, component of smartphones are “articles of manufacture” under this meaning and the federal Circuit erred in limiting t289 to the complete smartphone. The court declined to adopt a rule to determine whether the smartphone or its components were the “article” in this case as the parties did not brief the issue. Salman v United States

Salman sought review of the 9th Circuit decision affirming his insider trading conviction. The Court, resolving tension between the 9th Circuit decision and a 2nd Circuit decision requiring pecuniary or similar benefit to prove insider trading in the friend or relative context, unanimously affirmed. It held that under the Court’s Dirks precedent, it is sufficient to prove that the tipper, here Salman’s brother in law, disclosed the inside information intending to give Salman a gift of inside information, there was direct evidence in the record that Salman needed help and asked for inside information instead of cash and this was the equivalent of the brother in law trading on the information and giving the profit to Salman. It also held the 2nd Circuit requirement of pecuniary benefit was inconsistent with the Dirks decision.

State Farm Fire and Casualty Company v United States ex rel. Rigsby

State Farm sought review of the 5th Circuit decision affirming the denial of its motion to dismiss for violating the requirement to keep the qui tam complaint under seal. Resolving a circuit split, the Court unanimously affirmed. It held that there is no requirement in the text of the False Claims Act that a case be dismissed automatically when the seal duty is violated and this outcome is consistent with the structure of the Act which imposed the seal duty in order to keep criminal investigations secret and otherwise protect federal interests and this purpose would be defeated with an automatic dismissal remedy. It declined to adopt a rule setting out what factors should guide the discretion of the district court as to whether a motion to dismiss should be granted and noted the standards can be discussed in latter cases and held the issue of whether a lesser sanction should have been imposed was not preserved as State Farm did not seek any remedy besides dismissal.