Kamdem-Ouaffo v. Leblon

Kamdem-Ouaffo v. Leblon The Federal Circuit lacks jurisdiction because the appeal does not arise under the patent laws or any other basis conferring Federal Circuit jurisdiction under 28 U.S.C. § 1295. The matter is transferred to the Third Circuit pursuant to 28 U.S.C. § 1631. A reminder that the Federal Circuit's appellate jurisdiction is narrow—a case touching on trade secrets or other non-patent claims, even filed by a pro se litigant invoking patent-adjacent issues, will be transferred rather than dismissed if the wrong circuit is invoked. Transferred to the United States Court of Appeals for the Third Circuit. Appellant sued attorneys and a New Jersey state-court judge arising from a prior unsuccessful trade secret litigation; no patent claims were at issue. The Third Circuit had already affirmed dismissal; this appeal concerned only the district court's subsequent denial of post-judgment relief and recusal motions. Federal Circuit jurisdiction under § 1295(a)(1) requires the case to 'arise under' the patent laws—a threshold appellant failed to satisfy. Rather than dismiss for lack of jurisdiction, the court transferred to the Third Circuit under 28 U.S.C. § 1631 as the proper circuit. Nonprecedential order by Judges Lourie, Chen, and Stark, per curiam. standing / jurisdiction non-precedential standing / jurisdiction non-precedential standing / jurisdiction non-precedential