Plasmacam, Inc. v. Cncelectronics, LLC

Summary

In a patent infringement suit, the Federal Circuit held that it had appellate jurisdiction over an order enforcing a disputed settlement agreement because the order required specific performance (execution of the agreement) and was therefore an appealable injunction or final judgment. The court reversed the district court's enforcement of the settlement, finding clear error in limiting the "Covered Products" definition to past and current products; the record showed the parties had agreed on January 21 to a broader definition encompassing all components (including future products) manufactured, sold, or offered for sale by CNC. The case addresses contract formation and mutual assent in settlement agreements, applying Texas or federal common law, and clarifies that an order compelling execution of a settlement agreement is appealable under 28 U.S.C. § 1292(a)(1) or § 1295(a)(1).

Holdings

1. The court has jurisdiction either under 28 U.S.C. § 1292(a)(1) as an injunction because the order required specific performance (execution of the settlement agreement), or alternatively as a final judgment under 28 U.S.C. § 1295(a)(1) because the order evinced a clear intent to end the case.
2. The district court clearly erred in limiting the Covered Products to only past and current products plus updates and bug fixes, because the parties had agreed on January 21 that the definition would be 'all components manufactured, sold or offered for sale by CNC which incorporate digital torch height control.'

Questions Presented

1. Whether the Federal Circuit has appellate jurisdiction over the district court's order enforcing the settlement agreement.
2. Whether the district court erred in its interpretation of the 'Covered Products' term of the settlement agreement.

Disposition

reversed_and_remanded