In Murata Machinery USA v. Daifuku Co., Ltd., Appeal No. 2015-2094, the Federal Circuit upheld a district court’s refusal to lift a stay pending completion of inter partes review proceedings, but vacated the district court’s cursory refusal denying a request for a preliminary injunction and remanded for further proceedings.
Murata filed a patent infringement suit against Daifuku. Daifuku petitioned for inter partes review of all asserted patents and the district court stayed the litigation while the inter partes review was pending. Murata then filed motions to lift the stay and for entry of a preliminary injunction, which were both denied. The district court did not make any factual findings related to the preliminary injunction, separate and apart from its findings on the motion to lift the stay. Murata appealed.
On appeal, the Federal Circuit noted that it typically does not have interlocutory jurisdiction over a district court’s decision to stay or not stay a case. But in this case, because the stay was linked to the denial of a preliminary injunction, the issues were inextricably linked, giving the Federal Circuit discretion to consider the stay on appeal. The Federal Circuit declined to lift the stay because circumstances supporting the stay had not changed in a manner that would make the stay inappropriate. However, the Federal Circuit then held that the district court’s cursory denial did not satisfy FRCP 52(a)(2), which requires that a court state findings and conclusions supporting denial of a preliminary injunction. The Federal Circuit therefore remanded for further proceedings, noting that even a “limited analysis” may be sufficient to support denial of a preliminary injunction.