The following arguments will be available live to the public, both in-person and through online audio streaming. Access information will be available by 9 AM ET each day of argument
at: https://cafc.uscourts.gov/home/oral-argument/listen-to-oral-arguments/.
Friday, June 5, 2026, 10:00 A.M.
Micron Technology, Inc. v. Netlist, Inc., No. 2281-2282, Courtroom 402, Panel J
This appeal concerns whether the district court correctly determined that federal-question jurisdiction was lacking over state-law bad faith patent assertion claims and, on that basis, remanded two cases to state court.
Appellant, Netlist, filed two infringement lawsuits against appellee, Micron. The first asserted U.S. Patent No. 8,301,833 while the second asserted U.S. Patent Nos. 11,232,054 and 11,016,918. In response, Micron petitioned for IPR for each patent. The PTAB found all challenged claims unpatentable. Netlist appealed only the PTAB’s findings for the ’054 and ’918 patents. Netlist has not dismissed either infringement lawsuit.
Subsequently, Micron sued Netlist in Idaho state court twice under Idaho’s Bad Faith Assertions of Patent Infringement Act: once for the ’833 patent suit, and a second time for the ’054 and ’918 patents. Netlist removed both Idaho cases to district court. The district court remanded both back to state court holding no federal question jurisdiction existed for Micron’s claims because they did not involve a substantial patent law issue and federal resolution could upset the state-federal court system balance. Additionally, the court found no conflict between Idaho’s Act and federal patent law.
Netlist argues the district court improperly remanded the lawsuits to state court for two reasons. First, Micron’s claims of bad faith patent assertion arose under federal patent law. To determine bad faith liability, the court must determine whether Netlist’s infringement lawsuits were objectively baseless which raises questions of patent invalidity and infringement. Further, the issues are substantial because Micron’s bad-faith claims are based on pending federal patent litigations which risks inconsistent federal and state court judgments. Second, Micron’s claims affect validity of patent granting federal laws. Netlist states Micron’s lawsuits are to limit Netlist’s right to assert their patents and litigate infringement issues.
In response, Micron asks the court to affirm the district court’s decision, or alternatively, dismisses for lack of appellate jurisdiction. First, Micron’s state-law claims do not themselves raise patent law issues and any patent issues arise only in response to an anticipated defense. Further, federal jurisdiction would upset the state-federal court balance as Idaho has strong interests in protecting their citizens from unfair conduct in commerce. Second, Micron’s Idaho statutory claims do not render any federal laws void. Further, as Netlist owns all asserted patents through assignment, their property title is not derived from a federal officer, so the statute does not provide federal jurisdiction.
Friday, June 5, 2026, at 10:00 A.M.
Atlas Global Technologies LLC v. Lianzhou Technologies Co., Ltd., No. 25-1039, Courtroom 402, Panel J
This appeal arises from a patent infringement action related to Wi-Fi 6 technology. Atlas Global Technologies filed suit in Texas against Lianzhou Technologies Co. and TP-Link Corporation (collectively, Appellants), alleging infringement of several U.S. patents. A jury found infringement and awarded $37 million in damages.
On appeal, the principal dispute concerns personal jurisdiction. Lianzhou is a Chinese Corporation and TP-Link is located in Hong Kong. They first argue they lacked sufficient contacts with Texas because all design, manufacturing, and sales occur overseas. They assert that a separate U.S. entity, TP-Link USA, independently distributes and sells the products within the U.S. In their view, downstream sales by TP-Link USA in Texas cannot supply the necessary “minimum contacts” required for jurisdiction. They further argue that personal jurisdiction under 4(k)(2) is improper in Texas because jurisdiction in California would have been proper, where TP-Link USA is located.
Atlas responds that jurisdiction was proper under both traditional minimum-contacts principles and Rule 4(k)(2). Atlas argues that Appellants deliberately established and maintained a distribution channel that brings their products into the United States, including Texas, and that they benefit from nationwide sales through that channel, satisfying the minimum contacts standard through the stream of commerce. Atlas further contends jurisdiction under Rule 4(k)(2) was proper because Appellants argued they were not subject to personal jurisdiction in any State in the United States and instead tried to consent to jurisdiction in California.
Appellants also challenge the district court’s discovery rulings. During discovery, the parties disagreed over the scope and relevance of sales data from TP-Link USA. The district court ultimately required the use of third-party industry sales data and precluded Appellants from disputing those sales quantities with their own evidence. Appellants contend that these rulings were an abuse of discretion because they fully complied with discovery, while Atlas maintains that the court acted within its discretion in managing the record.
Finally, Appellants challenge the sufficiency of the evidence supporting infringement and damages. They argue that the accused conduct occurred outside the United States and that any domestic sales or marketing were carried out by the independent TP-Link USA. They also dispute whether the required showing for induced infringement was met. Atlas responds that the trial record contained sufficient evidence to support both direct and indirect infringement, as well as the jury’s damages award.
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