District Court Erred By Applying Collateral Estoppel To A General Jury Verdict That Could Have Rested On Multiple Grounds

In United Access Technologies, LLC v. CenturyTel Broadband Services LLC, No. 14-1347 (Fed. Cir. Feb. 12, 2015), the Federal Circuit reversed the district court's dismissal of the action on collateral estoppel grounds based on a prior action involving the same patents where a general jury verdict found against the patentee.

United Access Technologies, LLC ("United") owns U.S. Patent Nos. 5,844,596; 6,243,446; and 6,542,585 (collectively "the United Patents"). The asserted claims of the United Patents recite systems for using a landline telephone connection for both voice communication and data transmission. In 2002, Inline Connection Corporation ("Inline"), United's predecessor in interest, brought suit against EarthLink, Inc. ("EarthLink"), charging EarthLink with direct infringement of the United Patents by offering its customers an Internet connection service based on a broadband digital communications technology known as Asymmetrical Digital Subscriber Line ("ADSL"). EarthLink asserted that ADSL technology did not infringe the United Patents, and even if it did, EarthLink's accused ADSL system did not include a "telephone device" as required by the claims.

The jury in the EarthLink case returned a general verdict of noninfringement with respect to all of the asserted claims...