T-Mobile US, Inc. v. KAIFI LLC

T-Mobile US, Inc. v. KAIFI LLC The Federal Circuit held that it lacked appellate jurisdiction because the dispute was a Texas contract-interpretation issue that did not necessarily raise a substantial patent-law question under Gunn. The court transferred the appeal to the Fifth Circuit. Patent settlement payment triggers tied to PTO outcomes will not automatically create Federal Circuit jurisdiction if the case can be resolved as ordinary contract interpretation. Transferred to the United States Court of Appeals for the Fifth Circuit; each party bears its own costs. The settlement required an additional payment if any asserted claim of the '728 patent “survives the EPR”; the PTO later confirmed several asserted claims patentable without amendment. T-Mobile argued that “survives” required patent-law inquiries into changed claim scope, prosecution disclaimer, and alleged inequitable conduct during reexamination. The court held those patent issues were not necessarily raised because KAIFI’s breach-of-contract theory could be resolved by looking to the reexamination certificate and the ordinary meaning of “survives.” The court also found no substantial federal patent issue: the dispute was fact-bound, backward-looking, contract-specific, and did not implicate patent-law uniformity or a direct government interest. Because the district court had diversity jurisdiction and the case arose from the Eastern District of Texas, appellate jurisdiction belonged in the Fifth Circuit. standing / jurisdiction claim construction non-precedential attorney fees / sanctions standing / jurisdiction claim construction non-precedential attorney fees / sanctions standing / jurisdiction non-precedential