Centripetal Networks, LLC v. ITC

Centripetal Networks, LLC v. ITC The Federal Circuit affirmed the ITC's finding of no Section 337 violation as to the '370 Patent, holding that substantial evidence supported the Commission's determination that Centripetal's domestic industry product failed to satisfy the technical prong of the domestic industry requirement, and that Centripetal waived its challenges to the Commission's non-infringement findings by failing to address key claim limitations in its opening brief. Reinforces that ITC complainants must fully brief every appeal-dispositive infringement limitation in their opening brief or risk waiver, and that a domestic industry product must actually practice each claim limitation—not merely a functional approximation of the claimed 'device.' Affirmed The '917 Patent issues were mooted by the Federal Circuit's same-day affirmance of unpatentability in No. 24-1406, leaving only the '370 Patent in dispute. On the technical prong, the Commission found—and the Federal Circuit agreed on substantial evidence review—that Centripetal's RuleGATE ports are passive electrical interfaces that cannot be 'provisioned with rules' or 'generate log entries' as required by claim 22(b)–(f); the appliance itself, not the ports, stores and applies rules. On infringement, Centripetal waived its challenge to the Commission's findings on the 'identify' and 'communicate' aspects of limitations (e) and (f) of claims 22 and 43 by failing to address those specific findings in its opening brief. Centripetal also waived its limitation (h) 'communicate' argument on appeal by failing to address the Commission's own below-level waiver finding on that sub-element. Because both the domestic industry technical prong failure and the infringement waivers independently supported affirmance, the court declined to reach the patent ineligibility ground. domestic industry infringement waiver / forfeiture claim construction non-precedential domestic industry infringement waiver / forfeiture claim construction non-precedential domestic industry infringement waiver / forfeiture non-precedential