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Serta Simmons Bedding, LLC v. Casper Sleep Inc.

Summary Judgment Improper Because Settlement Mooted Case

Serta Simmons Bedding, LLC v. Casper Sleep Inc., __ F.3d __, 2020 WL 717771 (Fed. Cir. Feb. 13, 2020) (DYK, Plager, Stoll) (S.D.N.Y.: Hellerstein) (3 of 5 stars)

Fed Cir vacates summary judgment of noninfringement and affirms denial of fees motion. Serta Simmons’ patents relate to mattresses with a channel in which reinforcing materials can be located. The district court erred by issuing orders granting Casper’s motions for summary judgment notwithstanding that the parties had executed a settlement agreement and filed a motion to stay pending dismissal while summary judgment motions were pending. That the agreement contemplated some future performance (a money payment by Casper, filing of dismissal papers, and formal releases) did not mean a live controversy still existed. Per Exigent Technology, 442 F.3d 1301 (Fed. Cir. 2006), an enforceable settlement renders a case moot even if there is some performance yet to take place. The opinion notes that there are some circumstances (not present here) where a district court might refuse to enforce a settlement agreement, such as an agreement contrary to public policy.

The district court also erred by finding no jurisdiction to grant Serta Simmons’ motion to enforce the settlement agreement. Analyzing Kokkonen, 511 U.S. 375 (1982), and authority from the regional circuits, the opinion concludes, “under Federal Circuit law a district court has jurisdiction to enforce a settlement that resolves patent infringement claims if the motion to enforce is filed before the case is dismissed and the proceedings are ongoing.” Op. at 10.

Casper is not entitled to fees under § 285 because, in view of vacatur of summary judgment, Casper is not a prevailing party. It is not entitled to fees under § 1927 and the district court’s inherent power because the Settlement Agreement requires otherwise.

KEYWORDS: SETTLEMENT AGREEMENTS; JURISDICTION