Ninth Circuit, Section 230

Doe v. Meta Platforms — Ninth Circuit Holds Section 230 Bars Claims Over Facebook’s Role in Myanmar Genocide

The Ninth Circuit affirmed dismissal of claims by Rohingya plaintiffs alleging Facebook’s algorithm amplified anti-Rohingya violence in Myanmar, holding that Section 230 immunizes Meta from liability for algorithmically recommending third-party content — though two concurring opinions urged the court to reconsider its broad reading of Section 230.

Federal Circuit, Patent Subject Matter Eligibility

Constellation Designs v. LG Electronics — Federal Circuit Vacates § 101 Eligibility for Functional “Optimization” Claims, Affirms Eligibility for Specific Non-Uniform Constellation Claims

In a precedential opinion, the Federal Circuit drew a sharp § 101 line between functional ‘optimization’ claims that recite a result without specifying a concrete configuration and ‘constellation’ claims that recite specific non-uniform point arrangements. It vacated summary judgment of eligibility for the former and affirmed eligibility for the latter, while affirming the underlying jury verdict, willful-infringement finding, and damages award against LG.

Other International (Taiwan), Trade Secret, Federal

Taiwan v. Chen Li-ming (TSMC Trade Secret Case) — Taiwan Court Sentences Former Engineer to 10 Years for Leaking 2nm Chip Secrets to Tokyo Electron

Taiwan’s Intellectual Property and Commercial Court convicted four engineers and fined Tokyo Electron NT$150 million in the first-ever corporate conviction under Taiwan’s National Security Act, for theft of TSMC’s 2nm semiconductor process technology classified as a national core critical technology.

Section 230, State Courts

Meta Platforms v. Eighth Judicial District Court — Nevada Supreme Court Denies Meta’s Writ Petitions, Holding Section 230 and the First Amendment Do Not Bar State AG’s Addictive-Design Claims

In a consolidated order resolving three writ petitions, the Nevada Supreme Court applied its earlier TikTok and Snap decisions to reject Meta’s challenge to the State’s deceptive-trade-practices, products liability, negligence, and unjust enrichment claims over Messenger, Facebook, and Instagram — holding that personal jurisdiction was properly exercised and that neither Section 230 nor the First Amendment shields Meta from state-law claims aimed at platform design rather than third-party content.

District Courts, Section 230

Taddeo-Waite v. X Corp. — Section 230 Shields Platform from Subscriber’s Claims Over Algorithmic Amplification and Content Moderation

A federal magistrate judge held that Section 230 immunizes X (formerly Twitter) from a premium subscriber’s claims that the platform amplified harmful content via its recommendation algorithm and suppressed the subscriber’s own posts, rejecting the argument that algorithmic curation falls outside Section 230’s protections.

International Trade Commission, Utility Patent

Centripetal Networks v. ITC — Federal Circuit Affirms No Section 337 Violation for Keysight’s Cybersecurity Products After Multiple Waiver Findings

The Federal Circuit affirmed the ITC’s finding that Keysight Technologies did not violate Section 337 by importing cybersecurity products, holding that Centripetal failed to prove its own products practiced the asserted patents and waived multiple infringement arguments on appeal.

District Courts, Utility Patent

Headwater Research v. Verizon — Judge Gilstrap Wipes Out $175M Patent Verdict With Implied Waiver

Judge Gilstrap finds that Headwater Research LLC — which knew of Verizon’s patent infringement in 2017 but waited six years to file suit in order to maximize its damages window — engaged in conduct so inconsistent with an intent to enforce its rights that equity bars enforcement entirely, wiping out a $175 million jury verdict. The court holds that implied waiver survives the Supreme Court’s SCA Hygiene decision, which abolished laches, because waiver goes to liability rather than damages.

Copyright, District Courts

Moonbug Entertainment v. BabyBus — Court Denies Appellate Fees but Awards $280K for Extraordinary Copyright Enforcement Efforts

After prevailing in a $25.6 million copyright case over CoComelon character infringement, Moonbug sought $933K in additional fees. The court denied appellate fees — finding BabyBus’s curated appeal was objectively reasonable — but awarded $280K for extraordinary judgment enforcement work necessitated by BabyBus’s use of a shell entity to divert funds.

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