In June 2020, Mitek Systems sought a declaratory judgment to assert non-infringement of USAA's patents regarding its MiSnap software. The district court dismissed the case citing lack of jurisdiction, prompting an appeal. The Federal Circuit remanded it for a detailed analysis of Mitek's standing concerning possible infringement threats and indemnity. Upon review, the district court again found no credible threat, stating that MiSnap's functionality didn’t directly infringe the patents, nor did Mitek face imminent liability. Mitek appealed the dismissal of declaratory relief.
The district court concluded Mitek had no reasonable apprehension of suit, determining that MiSnap did not practice all claim elements, thus undermining the legitimacy of Mitek's claims.
The Federal Circuit's remand instructed the district court to categorize the 12(b)(1) challenge, emphasizing a thorough evaluation of Mitek's standing on direct and indirect infringement.
#declaratory-judgment #intellectual-property #subject-matter-jurisdiction #patent-infringement #legal-proceedings
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