The U.S. Court of Appeals for the Federal Circuit issued a precedential decision Wednesday in Micron Technology, Inc. v. Longhorn IP LLC, dismissing Micron's appeal of a district court order that imposed an $8 million bond. The bond was required under Idaho's Bad Faith Assertions of Patent law, a state statute aimed at curbing abusive patent litigation.
Micron had appealed the bond order, but the Federal Circuit found it lacked jurisdiction to hear the appeal at this stage. The appellate court did not rule on whether the bond was proper, only that the order was not immediately appealable. As a result, the $8 million bond remains in effect while the case continues in the district court.
The ruling is notable because it clarifies the procedural limits on appealing bond orders in patent cases involving state anti-troll statutes. By dismissing for lack of jurisdiction, the Federal Circuit leaves the district court's discretion intact and requires parties to wait for a final judgment before seeking appellate review of such bond conditions.