Katana Silicon Technologies, LLC v. Micron Technology, Inc., et al.; Micron Technology, Inc., et al. v. Longhorn IP, LLC

Summary

The United States District Court for the District of Idaho denied Longhorn IP, LLC and Katana Silicon Technologies, LLC's motions to stay proceedings pending IPR appeal or, alternatively, to modify or waive an $8 million bond. The court held that the stay request was moot after the Federal Circuit resolved the appeal and concluded that the parties had not shown good cause to reconsider or reduce the bond. The court authorized either entity to deposit the full $8 million in the Court Registry Investment System and directed that the order be entered in both connected cases.

Holdings

1. The request to stay the bond order was moot because the Federal Circuit had resolved the appeal and Longhorn/Katana represented that they would not seek en banc review or certiorari.
2. The court declined to waive the $8 million bond requirement because Katana's manager merely declared that Katana was willing to maintain sufficient cash reserves and provided no evidence that Katana's current assets equaled the proposed bond amount.
3. The court refused to reduce the bond amount attributable to the invalidated patents because $750,000 per patent remained a good-faith estimate of Micron's total litigation costs.
4. The court declined to reconsider or reduce the bond based on the PTAB's refusal to institute IPR concerning the third patent because the decision was not new material information, did not establish clear error, and did not undermine the factors supporting the original reasonable-likelihood finding.

Questions Presented

1. Whether the request to stay enforcement of the bond order pending Federal Circuit review was moot after the Federal Circuit resolved the appeal.
2. Whether Katana's declaration that it would maintain cash reserves equal to the bond amount established good cause to waive the bond requirement under Idaho Code section 48-1707.
3. Whether the PTAB's invalidation of two patents required reduction of the bond amount.
4. Whether the PTAB's refusal to institute inter partes review of the third patent constituted new material information or clear error warranting reconsideration of the bond order.

Disposition

other