LINFO IP, LLC v. TRUSTPILOT, INC.

LINFO IP, LLC v. TRUSTPILOT, INC. The Federal Circuit held that the settlement and license ended the Article III controversy between Linfo and Trustpilot. Trustpilot’s reserved right to participate in the appeal did not preserve jurisdiction because Trustpilot no longer had a concrete, outcome-tethered stake in the invalidity ruling. A patentee that settles and licenses the accused infringer during appeal may lose the ability to obtain appellate review of an adverse invalidity ruling if the agreement eliminates any live dispute between the parties. Appeal dismissed as moot; no costs. The district court had dismissed Linfo’s infringement claims after finding the asserted ’428 patent claims invalid under Alice and § 101. During the appeal, the parties entered a settlement agreement granting Trustpilot a worldwide, irrevocable license to the patent, settling all claims, and requiring dismissal with prejudice if the district-court case resumed. The Federal Circuit treated the agreement as eliminating Trustpilot’s stake in infringement, validity, and enforceability despite a clause preserving Trustpilot’s ability to participate in the appeal. The court distinguished cases where settlement consideration remained tied to the appellate outcome; here, Linfo failed to show a legitimate, continuing controversy. Because the mootness resulted from the patentee’s voluntary settlement, the court dismissed the appeal rather than reaching the § 101 merits. § 101 standing / jurisdiction non-precedential infringement § 101 standing / jurisdiction non-precedential infringement standing / jurisdiction non-precedential