Puritan Medical Products Co. v. Copan Italia S.p.A.
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The Supreme Judicial Court affirmed a summary judgment entered in the Business and Consumer Docket in favor of Copay Italia S.p.A. on Puritan Medical Products Company’s claim that Copay violated Maine’s Actions for Bad Faith Assertion of Patent Infringement statute, Me. Rev. Stat. 14, 8701-8702, holding that Puritan’s claim was preempted by federal patent law.
Although the lower court granted summary judgment for Copan after finding no genuine issues of material fact and determining that Copay was entitled to judgment as a matter of law, Copan filed a cross-appeal challenging the court’s conclusion that Puritan’s claim was not preempted by federal law. The Supreme Judicial Court affirmed, holding (1) in its preemption analysis, the trial court conflated the test for federal preemption with the test for federal jurisdiction; and (2) federal patent law preempted Puritan’s state law claim, and therefore, summary judgment in favor of Copay was properly granted on that basis.
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