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United States Federal Circuit


A123 Sys., Inc. v. Hydro-Quebec, 10-1059

In plaintiff's suit seeking a declaration of noninfringement and invalidity of two patents related to a genus of lithium based cathode materials, district court's denial of plaintiff's motion to reopen and dismissal of the declaratory judgment action is affirmed where: 1) because the defendant had acquired less than all substantial rights in the patents in suit, University of Texas (UT) is a necessary party to plaintiff's declaratory judgment action; 2) UT's waiver of Eleventh Amendment immunity in a patent infringement suit in the Northern District of Texas did not result in a waiver of immunity in this separate infringement action, and absent such a waiver, UT cannot be joined; and 3) because three of the four Rule 19(b) factors weigh in favor of holding UT to be an indispensable party, UT was not only a necessary party, but also and indispensable party, making dismissal appropriate.

Appellate Information

  • Decided 11/10/2010
  • Published 11/10/2010

Judges

Court

  • United States Federal Circuit

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