Sandisk Corp. v. ST Microelectronics, Inc.
United States Court of Appeals for the Federal Circuit
480 F.3d 1372 (2007)
ST Microelectronics (ST) (defendant) approached SanDisk (plaintiff) about licensing certain patents, and during a meeting ST asserted SanDisk had infringed those patents while also stating it had no intention of suing SanDisk. After further licensing discussions stalled, SanDisk -- confident in its own position -- filed a declaratory judgment action seeking a ruling of non-infringement and patent invalidity; ST moved to dismiss for lack of subject-matter jurisdiction, and the district court agreed, finding no actual controversy because SanDisk lacked an objectively reasonable apprehension of being sued.
Whether a court has subject-matter jurisdiction over a declaratory judgment action when a patentee has asserted patent rights against another party and that party denies infringement.