Centripetal Networks v. ITC — Federal Circuit Affirms No Section 337 Violation in Cybersecurity Patent Dispute

Background

Centripetal Networks is a cybersecurity company that markets a network security platform called CleanINTERNET, comprising RuleGATE, ACT (Advanced Cyber Threat), and QuickTHREAT components. In 2022, Centripetal filed a complaint at the International Trade Commission (ITC) — a specialized federal tribunal with the power to block importation of infringing goods — against Keysight Technologies, whose Vision product line (Vision One, Vision X, Vision 7300, Vision 7303, Vision Edge 1S, and Trade Vision) provides network traffic monitoring and security enforcement tools.

Centripetal asserted three patents: U.S. Patent No. 9,264,370 (“Correlating Packets in Communications Networks”), U.S. Patent No. 10,193,917 (“Rule-Based Network-Threat Detection”), and U.S. Patent No. 10,284,526. After a full hearing, an administrative law judge (ALJ) found no Section 337 violation as to any patent, and the full ITC Commission affirmed. Centripetal appealed to the Federal Circuit on the ‘370 and ‘917 patents; the ‘526 patent was not appealed.

The Court’s Holding

The Federal Circuit affirmed the ITC’s no-violation finding across the board. For the ‘917 patent, the Federal Circuit’s companion decision in Case No. 24-1406 (also decided April 23, 2026) found all ‘917 patent claims unpatentable for obviousness — which mooted the ITC issues on that patent entirely. For the ‘370 patent, the court upheld the ITC’s finding on two independent and sufficient grounds.

First, Centripetal failed the domestic industry requirement’s technical prong. To use the ITC, patent owners must show not just that someone is infringing their patent, but that a U.S. industry “practices” the patent — meaning their own product maps onto the patent’s claims. Centripetal argued that its CleanINTERNET hardware and software combination satisfied the ‘370 patent’s “device” limitations, but the ITC found — and the Federal Circuit agreed — that substantial evidence supported the conclusion that Centripetal’s RuleGATE appliance ports could not, on their own, satisfy claims (b) through (f) of claim 22. Second, Centripetal waived any challenge to the ITC’s noninfringement finding by failing to adequately preserve it during the proceedings below.

Key Takeaways

• ITC complainants must rigorously map their own products to every claim element before filing — a gap in the technical prong analysis can doom an entire ITC case even with compelling infringement evidence against the accused products.
• When an IPR proceeding simultaneously invalidates a patent, it can moot companion ITC proceedings asserting the same patent — coordinating PTAB and ITC strategy is essential.
• Arguments not preserved at the ITC administrative level constitute waiver on Federal Circuit appeal — the full record must be made before the Commission.
• Cybersecurity companies pursuing ITC relief should conduct rigorous internal claim-charting of their own products before filing, not just an infringement analysis of accused products.

Why It Matters

The ITC has become an increasingly important forum for patent holders seeking quick, powerful relief — an exclusion order blocking importation can be more impactful than money damages. But this case illustrates a common and costly pitfall: companies that hold patents they believe are practiced by their own products may still fail the ITC’s domestic industry test if their litigation team cannot precisely map each claim element to what those products actually do. The lesson for cybersecurity companies and other technology patent holders considering the ITC is to begin with a careful internal claim chart — the technical prong analysis is often the hardest part of an ITC case, not the infringement side.