The equitable doctrine of collateral estoppel protects a party
from having to re-litigate an issue that has already been fully and
fairly adjudicated. In Nestlé USA, Inc. v. Steuben
Foods, Inc. the Federal Circuit said that application of
collateral estoppel is not limited to construing only identical
patent claims; but instead, it extends to terms across related
patents. Case No. 2017-1193 (Fed. Cir. Mar. 13,
2018).
Nestlé and Steuben Foods were simultaneously involved in
multiple litigation disputes. Two of these disputes are relevant to
the court's collateral estoppel decision: (1) an IPR proceeding
and corresponding appeal regarding Patent No. 6,945,013 owned by
Steuben Foods (the '013 proceeding) (IPR2014-01235 and Fed.
Cir. App. No. 16-1750) and (2) an IPR proceeding regarding related
Patent No. 6,481,468, also owned by Steuben Foods (the '468
proceeding). See IPR2015-0049. The '013 and the
'468 patents both claim priority to the same U.S.
