District Court’s Refusal to Hear Declaratory Judgment Suit Found to be Abuse of Discretion

Applying the "abuse of discretion" standard, the U.S. Court of Appeals for the Federal Circuit reversed a district court’s dismissal of a declaratory judgment suit and remanded the case. Electronics For Imaging, Inc. v. Jan R. Coyle, Case No. 04-1266, (Fed. Cir., Jan. 5, 2005) (Lourie, J.)

Electronics For Imaging Inc. (EFI) specializes in network printing solutions. It sells its products to companies such as Canon Inc., Hewlett-Packard Company and Xerox Corporation, which in turn incorporate EFI’s technology into their own print servers, printers and copiers. EFI is a Delaware corporation with its principal place of business in California. Jan Coyle, a Nevada resident, is a listed inventor on two patents directed to printing technology. Kolbet Labs is a Nevada sole proprietorship owned by Daniel Kolbet, who is also a Nevada resident and an inventor listed on both patents.