EPIC TECH, LLC v. PEN-TECH ASSOCIATES, INC.

EPIC TECH, LLC v. PEN-TECH ASSOCIATES, INC. The Federal Circuit vacated because the district court did not provide enough reasoning to permit meaningful review of its denial of sanctions and fees. The panel did not decide whether Epic Tech or its counsel violated Rule 11 or whether Pen-Tech is entitled to fees. When a fee or sanctions motion is tied to alleged notice of § 101 invalidity, a district court must address that validity-based theory with enough specificity for appellate review. Vacated and remanded for further proceedings; costs awarded to Pen-Tech. The asserted patent covered an electronic sweepstakes system; the district court held the asserted claims invalid under § 101 at summary judgment. Pen-Tech argued Epic Tech and its counsel had notice of potential invalidity from Alice, PTO § 101 rejections in related applications, and the Fusion Skill decision invalidating claims of a related patent. The Federal Circuit held the district court's focus on Epic Tech's pre-suit infringement investigation did not answer the separate question whether Epic Tech reasonably investigated or pursued validity in light of those indicators. The panel also found the district court did not adequately address the PTO office actions or the Fusion Skill ruling as potential notice of § 101 problems. The court vacated only for insufficient explanation and expressly declined to decide entitlement to sanctions or fees. § 101 attorney fees / sanctions remand precedential infringement § 101 attorney fees / sanctions remand precedential infringement attorney fees / sanctions remand § 101 precedential