On April 20, 2015, the U.S. Supreme Court remanded a case back to the U.S. Court of Appeal for the Federal Circuit for further consideration in light of its January decision in Teva v. Sandoz, in which the U.S. Supreme Court held that the Federal Circuit must generally apply a “clear error” standard, not de novo, when reviewing a district court’s claims construction. 

In the case, the plaintiff Azure Networks, LLC, sued Marvell in the Eastern District of Texas in 2011, alleging that Marvell’s products infringed Azure’s patent on Bluetooth technology. After the district court construed a particular patent term, Azure conceded that Marvell did not infringe the patent-in-suit and the court entered judgment in favor of Marvell in 2013. Azure appealed the construction to the Federal Circuit, and in November 2014, the Federal Circuit found in favor of Azure and reversed the district court’s construction.

Marvell filed a petition for writ of certiorari to the U.S. Supreme Court, arguing that the Federal Circuit reviewed the district court’s construction under the de novo standard of review, contrary to the Court’s Teva decision. Specifically, Marvell argued that the Federal Circuit made “factual findings contrary to those of the district court without identifying clear error.” 

The U.S. Supreme Court issued a one-page order, remanding the case back to the Federal Circuit for further consideration in light of Teva. 

CSR PLC v. Azure Networks, LLC, United States Supreme Court, No. 14-976.