Term: 2016
Docket: 15-927
Sca Hygiene Prods. Aktiebolag v. First Quality Baby Prods., Llc
- Pro
15-927 SCA HYGIENE PRODUCTS V. FIRST QUALITY BABY PRODUCTS DECISION BELOW: 807 F.3d 1311 CERT. GRANTED 5/2/2016 QUESTION PRESENTED: In Petrella v. Metro-Goldwyn-Mayer, 134 S. Ct. 1962 (2014), the Court held that the defense of laches cannot be used to shorten the three-year copyright limitations period set forth in 17 U.S.C. § 507(b), observing that "we have never applied laches to bar in their entirety claims for discrete wrongs occurring within a federally prescribed limitations period." 134 S. Ct. at 1974. In reaching its decision, the Court noted that the Federal Circuit follows a contrary rule in the patent setting, applying laches to bar infringement claims accruing within the six-year limitations period prescribed in 35 U.S.C. § 286, but stated: "[w]e have not had occasion to review the Federal Circuit's position." Petrella, 134 S. Ct. at 1974 n.15 (discussing A.G. Aukerman Co. v. R.L. Chaides Constr. Co., 960 F.2d 1020 (Fed. Cir. 1992) (en banc)). Following Petrella, the Federal Circuit convened en banc in this matter to consider the conflict between Petrella and Aukerman. All judges of the court agreed that there is "no substantive distinction material to the Petrella analysis" between the copyright and patent limitations periods. Pet. App. 18a. Nevertheless, in a 6-5 decision, the court reaffirmed its position in Aukerman and held that laches may be used to bar patent infringement claims accruing within the six-year limitations period. The question presented is: Whether and to what extent the defense of laches may bar a claim for patent infringement brought within the Patent Act's six-year statutory limitations period, 35 U.S.C. § 286. LOWER COURT CASE NUMBER: 2013-1564
The U.S. Supreme Court case SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC (2016) revolved around the issue of laches - a legal doctrine that bars those who take too long to assert a legal right from making a claim - in patent infringement cases. The plaintiff, SCA Hygiene Products Aktiebolag, accused First Quality Baby Products of infringing on its patent for adult diapers. However, First Quality argued that since SCA took seven years to file the lawsuit after notifying them about the alleged infringement, they were barred by laches from pursuing their claim. The Federal Circuit agreed with this argument and dismissed the case based on laches defense. However, upon appeal to the Supreme Court it was held that laches cannot be used as a defense against damages where claims are brought within statutory six-year limitation period under Patent Act 1952 Section 286; thus overruling Federal Circuit's judgment which allowed such use of Latches Defense.
In the dissenting opinion for SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC, Justice Breyer argued that laches should be a valid defense in patent infringement cases even when they are brought within the six-year statutory limitations period set by Congress. He pointed out that historically, courts of equity have often applied laches to such cases and there is no evidence suggesting Congress intended to exclude this traditional remedy from patent law when it enacted the 1952 Patent Act. Furthermore, he noted that allowing laches as a defense would not undermine the purpose of statutes of limitation because these two principles serve different purposes: while statutes of limitation encourage plaintiffs to bring their claims promptly, laches protect defendants against unreasonable delays in bringing claims which might result in unfair prejudice or disadvantage.
