Critical-Vac Filtration Corp. v. Minuteman International, Inc.’s Empirical Analysis

Citation profile

5 federal appellate · 6 district · 1 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “`essential facts of the claims [must be] so logically connected that considerations of judicial economy and fairness dictate that all the issues be resolved in one lawsuit.'”

   2 later decisions quote this exact passage · from the majority
   e.g. 472 F. Supp. 2d 582 - In Re Parmalat Securitìes Litigation · Jones v. Ford Motor Credit Co.

2. “Antitrust claims based on patent misuse, such as the counterclaims in Mercoid , are likely to involve factual issues distinct from those involved in patent infringement litigation between the same parties.... In contrast, antitrust claims based on patent invalidity, such as C-Vac’s claims in the instant case, will generally involve the same factual issues as those involved in patent infringement litigation between the same parties — as they do here. As a result, an exception to Rule 13(a) for at least some patent misuse claims will, in fact, generally be consistent with the purposes of that rule — that is, with the resolution of all “logically connected” claims between the same parties in the same proceeding — whereas an exception to Rule 13(a) for patent invalidity claims would generally contradict the purpose of that rule.”

   1 later decision quote this exact passage · from the majority
   e.g. Eon Laboratories, Inc. v. SmithKline Beecham Corp.

3. “Though Mercoid were barred in the present case from asserting any defense which might have been interposed in the earlier litigation, it would not follow that its counterclaim for damages would likewise be barred. That claim for damages is more than a defense; it is a separate statutory cause of action. The fact that it might have been asserted as a counterclaim in the prior suit by reason of Rule 13(b) of the Rules of Civil Procedure does not mean that the failure to do so renders the prior judgment res judicata as respects it.”

   1 later decision quote this exact passage · from the majority
   e.g. Eon Laboratories, Inc. v. SmithKline Beecham Corp.