ParkerVision, Inc. v. Qualcomm Incorporated

ParkerVision, Inc. v. Qualcomm Incorporated The Federal Circuit held that it lacked appellate jurisdiction because there was no final judgment: Rule 54(b) did not permit a partial final judgment resolving only some asserted claims of the same patent while other asserted claims of that patent remained unresolved. The court also denied ParkerVision’s request to reassign the case to a different district judge on remand. The decision reinforces that, for Rule 54(b) purposes, infringement generally tracks the patent-level cause of action—not individual patent claims—so partial appeals on subsets of claims from the same patent may not be available while other claims remain pending. Appeal dismissed for lack of jurisdiction; request for reassignment denied; each party to bear its own costs. The district court’s Rule 54(b) judgment covered receiver claims of both patents, but the '940 patent also had unresolved transmitter claims pending below. The Federal Circuit treated infringement of a patent as a single cause of action for Rule 54(b) purposes, relying on §§ 281 and 271 and prior authority distinguishing civil-procedure “claims” from patent claims. Because the receiver claims of the '940 patent were not a separate cause of action from the unresolved transmitter claims of the same patent, the partial judgment was not final. The court also rejected ParkerVision’s attempt to salvage jurisdiction over the fully resolved '907 patent, because the district court had not separately certified a Rule 54(b) judgment limited to that patent. Applying Eleventh Circuit law, the court found no basis for the severe remedy of reassignment, citing the judge’s compliance with the prior remand and the waste that would result from transferring a complex, long-running case. standing / jurisdiction claim construction injunction / stay remand precedential infringement standing / jurisdiction claim construction injunction / stay remand precedential infringement standing / jurisdiction remand precedential