In this case involving a patent directed to systems and methods for online searching, the plaintiffs ("Google") sought a declaratory judgment of noninfringement, and the defendant ("GeoTag") counterclaimed with patent-infringement allegations. The district court rejected GeoTag's assertion that Google's declaratory-judgment claims lacked sufficient detail to warrant the exercise of subject-matter jurisdiction, and granted summary judgment of noninfringement to Google. The Federal Circuit affirmed. It concluded that even if Google's declaratory-judgment claim was defective, the district court had subject-matter jurisdiction over GeoTag's patent-infringement counterclaim. More specifically, the Federal Circuit concluded that even if there is a defect in a complaint seeking a declaratory judgment of noninfringement, a district court retains jurisdiction over a patent-infringement counterclaim that is not a "conditional" counterclaim. Because GeoTag's counterclaim was not conditional, the Federal Circuit concluded that this case was distinguishable from Microsoft Corp. v. DataTern, Inc., 755 F.3d 899 (Fed. Cir. 2014), which held that a conditional counterclaim cannot establish subject-matter jurisdiction over a declaratory-judgment complaint. Moreover, the Federal Circuit concluded that the patent-infringement counterclaim would vest the district court with subject-matter jurisdiction regardless of whether the counterclaims are deemed "compulsory" or "permissive" under Federal Rule of Civil Procedure 13(a)-(b). On the merits, the Federal Circuit affirmed the district court's grant of summary judgment to Google.
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