Federal Jurisdiction and Implicating Federal Patent Law: Lighting Sci. Group Corp. v. Koninklijke Philips Elecs. N.V.

Federal Jurisdiction and Implicating Federal Patent Law: Lighting Sci. Group Corp. v. Koninklijke Philips Elecs. N.V.

In Lighting Science Group Corporation, et al. v. Koninklijke Philips Electronics N.V., et al., 2008 U.S. Dist. LEXIS 43959 (E.D. Cal. June 3, 2008), plaintiffs filed a state court action against their competitors in the field of commercial lighting applications. In filing the action, plaintiffs sought to recovery on numerous claims, including breach of the covenant of good faith and fair dealing, breach of fiduciary duty, intentional and negligent interference with plaintiffs' contracts, intentional and negligent interference with plaintiffs' prospective business relations, violation of California Business & Professions Code section 17200 et seq., and misappropriation of confidential information (Cal. Bus. & Prof. Code § 3426 et seq.). Thereafter, defendants removed the action to the United States District Court for the Eastern District of California, contending that the court had jurisdiction because the action implicated federal patent law. In addressing the jurisdictional issue, the court stated that under Christianson v. Colt Indus. Operating Corp., a district court had to first examine all of the theories under which a plaintiff might recover on a certain claim and next determine that the resolution of a substantial question of federal patent law was necessary for recovery on that claim. The court held plaintiffs had pled four causes of action that arguably implicated federal patent law: breach of covenant of good faith and fair dealing, breach of fiduciary duty, violation of California Business & Professions Code § 17200, et seq., and misappropriation of confidential information. However, in remanding, the court held that none of these causes of action required the resolution of questions of federal law in order for plaintiffs to succeed.

  • Tags: