Satterlee Defeats Unjust Enrichment Claims Based on Patent Inventorship Allegations


Satterlee partner Mario Aieta successfully argued for the dismissal of the plaintiff’s unjust enrichment claim asserted in an inventorship dispute pending in the United States District Court for the District of Colorado.  Plaintiff alleges that a series of patents owned by a Colorado-based medical devices company are based on a device invented by plaintiff that was misappropriated by one of the defendants, an inventor named in the disputed patents.  In addition to claims for correction of inventorship under 35 U.S.C. § 256, plaintiff asserted a claim for unjust enrichment against the defendant inventor, asserting that plaintiff was entitled to some part of the compensation paid to the defendant inventor in connection with his role as an inventor of the patented devices.  Defendants, represented by Satterlee, moved to dismiss the unjust enrichment claim. The court agreed that the unjust enrichment claim was barred by the applicable statute of limitations because it accrued when the first disputed patent issued, not when the defendant inventor first received compensation in connection with the inventions.