United States of America: United States Court of Appeals for Federal Circuit vacates United States International Trade Commission decision on patent infringement investigation (Case No. 23-1509)

On 7 March 2025, the United States Court of Appeals for the Federal Circuit vacated a decision by the United States International Trade Commission (ITC) and remanded the case with instructions to dismiss it as moot. The ruling concerned cross-appeals filed by AliveCor, Inc. and Apple Inc. in connection with ITC Investigation No. 337-TA-1266. The ITC had previously determined that Apple violated 19 U.S.C. § 1337 by infringing AliveCor’s ’941 and ’731 patents, which relate to systems for measuring and analyzing physiological data, and had issued a limited exclusion order restricting the importation of certain Apple Watch products. However, the Federal Circuit noted that it had already affirmed the Patent Trial and Appeal Board’s decisions invalidating all claims of the asserted patents (’499, ’731, and ’941) in parallel inter partes review proceedings. As a result, the court concluded that the ITC’s infringement investigation was moot and ordered the underlying decision vacated and the case dismissed.