CLS Bank v. Alice Corporation
Loughlin v. Ling

Rates Technology v. Speakeasy

Plaintiff-appellant Rates Technology Inc. appeals from a judgment granting defendants-appellees’ motion to dismiss entered by the United States District Court for the Southern District of New York (Denise Cote, J.) on May 10, 2011. We hold that, under the Supreme Court’s decision in Lear, Inc. v. Adkins, 395 U.S. 653 (1969), a clause in a settlement agreement that bars a patent licensee from later challenging the patent’s validity is void for public policy reasons if the settlement was entered into prior to the initiation of litigation between the parties. We accordingly AFFIRM the district court’s judgment.

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