Farmobile, LLC v. Farmers Edge Inc.

Farmobile, LLC v. Farmers Edge Inc.

The Prothonotary correctly concluded that the ownership allegations in the Amended Statement of Defence are ancillary to the patent infringement action and thus within Federal Court jurisdiction, but the Amended Counterclaim is a standalone contractual claim seeking declaration of ownership and consequential relief that is principally contractual and therefore plainly outside the Federal Court's jurisdiction; the stay was properly refused as no irreparable harm was shown.

Citation
2018 FC 1269
Parties
Plaintiff/defendant by Counterclaim: Farmobile, LLC; Defendant/plaintiff by Counterclaim: Farmers Edge Inc.
Court
Federal Court
Jurisdiction
Canada
Judgment Date
14 December 2018
Procedural Posture
Patent Infringement / Appeal From Prothonotary's Orders (motions to Strike and Stay)
Outcome
Both appeals dismissed
Legal Topics
Jurisdiction, Motions to Strike, Counterclaim, Ownership of Patent, Stay of Proceedings, Contract Interpretation
Source Language
English
Intellectual Property Patent Law Civil Procedure Federal Court Jurisdiction Jurisdiction Motions to Strike Counterclaim Ownership of Patent +2 more

Case Brief

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Parties

Farmobile, LLC

Plaintiff/defendant by Counterclaim

Farmers Edge Inc.

Defendant/plaintiff by Counterclaim

Procedural Posture

Patent Infringement / Appeal From Prothonotary's Orders (motions to Strike and Stay)

Legal Issues

  1. 1 Whether the Federal Court has jurisdiction to determine ownership of a patent where resolution requires contractual interpretation
  2. 2 Whether portions of the Amended Statement of Defence should be struck for lack of jurisdiction
  3. 3 Whether portions of the Amended Counterclaim should be struck as beyond the Federal Court's jurisdiction

Ratio Decidendi

The Prothonotary correctly concluded that the ownership allegations in the Amended Statement of Defence are ancillary to the patent infringement action and thus within Federal Court jurisdiction, but the Amended Counterclaim is a standalone contractual claim seeking declaration of ownership and consequential relief that is principally contractual and therefore plainly outside the Federal Court's jurisdiction; the stay was properly refused as no irreparable harm was shown.

Court Disposition

Both appeals dismissed

Orders

  • Both appeals are dismissed
  • If necessary, the parties may make brief written submissions with respect to the costs of these appeals