KAMDEM-OUAFFO v. NATURASOURCE INTERNATIONAL, LLC [ORDER]

KAMDEM-OUAFFO v. NATURASOURCE INTERNATIONAL, LLC [ORDER] The Federal Circuit dismissed the appeals, holding that collateral challenges to the district court’s remand order were barred by 28 U.S.C. § 1447(d). The court also held that the remaining challenges were frivolous, including recusal arguments based on disagreement with prior rulings and attempts to revive dismissed actions based on a forfeited challenge to the state-court judgment. The order reinforces that appellate courts will not entertain indirect attacks on unreviewable remand orders or repetitive post-judgment challenges lacking a non-frivolous jurisdictional or merits basis. Appeals dismissed; all pending motions denied; each party to bear its own costs. The underlying dispute involved alleged misappropriation of proprietary pet food flavoring information, not a patent claim. The district court had remanded the removed state action for lack of subject-matter jurisdiction and untimely removal; § 1447(d) barred appellate review of that remand order and collateral reconsideration challenges. The Federal Circuit did not resolve whether it or the Third Circuit had appellate jurisdiction because dismissal was appropriate in any event. Recusal arguments based only on disagreement with prior district-court rulings supplied no colorable basis for relief. Attempts to revive dismissed federal actions based on an allegedly void state-court judgment were deemed frivolous, particularly where the Third Circuit had already treated that argument as forfeited. standing / jurisdiction remand waiver / forfeiture claim preclusion non-precedential standing / jurisdiction remand waiver / forfeiture claim preclusion non-precedential standing / jurisdiction remand waiver / forfeiture