CARTESSA AESTHETICS, LLC v. ITC
International Trade Commission
Holding
The Federal Circuit held that the appeals were moot because the asserted patent had expired and the ITC can provide only prospective relief. Potential indirect effects of the ITC determination in PTO proceedings did not preserve a live Article III controversy.
Why It Matters
The order reinforces that expiration of the asserted patent ordinarily moots an ITC appeal and supports vacatur of the Commission determination, even where a party points to possible collateral effects in PTO proceedings.
Full Summary
Key Points
- The ITC found a Section 337 violation based on Cartessa's infringement of Hydrafacial's patent but suspended enforcement of an exclusion order because the patent was about to expire.
- After expiration, Cartessa sought dismissal and vacatur; the Commission did not oppose, while Hydrafacial argued the ITC decision could matter in ongoing PTO matters.
- The court applied its Section 337 mootness line of cases, reasoning that once the patent expires, the ITC's prospective remedies no longer provide a live controversy.
- The court rejected asserted PTO collateral consequences as too indirect and dependent on non-party action to defeat mootness.
- The final determination was vacated and the investigation remanded for dismissal as moot.
How this summary was made: Drafted with AI from the court's opinion or order. Read the document itself before relying on the summary. Editorial policy
New to District court litigation? Start with PTAB vs. District Court: Where to Challenge a Patent’s Validity
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