Addressing the issue of claim preclusion, the US Court of
Appeals for the Federal Circuit affirmed the district court's
holding that patent infringement customer lawsuits were precluded
in view of a prior action against a website proprietor that was
dismissed with prejudice and involved the same patents and accused
product. In re: PersonalWeb Techs, LLC, Case No. 19-1918
(Fed. Cir. June 17, 2020) (Bryson, J.).
The patents at issue, referred to as the "True Name"
patents, are directed to systems creating a substantially unique
identifier for each data item through the use of hash functions. In
2011, PersonalWeb sued Amazon and one of Amazon's customers,
Dropbox, for patent infringement in the Eastern District of Texas
based on use and sale of the Amazon Simple Storage Service (S3).
After the district court issued its claim construction order,
PersonalWeb stipulated to the dismissal of all claims against
Amazon with prejudice. PersonalWeb had previously dismissed
