IP Law Daily, PATENT—E.D. Mich.: Infringement case over circuit board assemblies in vehicles moves forward, (Oct 1, 2025)

By Brian Craig, J.D.

Issue preclusion does not bar the patent infringement claims where ownership of intellectual property rights was not decided by the Michigan state court.

Concluding that prior state court litigation does not have preclusive effect, the federal district court in Detroit, Michigan, has ruled that patent infringement and copyright infringement claims brought by an electronic parts supplier against Futaba Corporation of America (“Futuba”) over printed circuit board assemblies used in dashboards for vehicles can proceed. In denying Futaba’s motion to dismiss, the court held that issue preclusion does not bar the patent infringement claims because the federal court could not determine that the ownership of intellectual property rights relating to the circuit board assemblies was conclusively determined in the earlier Michigan court case. The court narrowly dismissed any copyright infringement claims based on alleged acts of infringement beyond the statute of limitations but largely allowed the copyright infringement claim over software source code to proceed (UUSI, LLC v. Futaba Corporation of America, No. 2:24-cv-13104-SKD-CI (E.D. Mich. Sept. 30, 2025)).

UUSI, LLC, doing business as Nartron manufactures electronic systems and components for vehicles. The electronic parts supplier in Michigan engineers and produces printed circuit board assemblies (PCBAs) that are designed specifically for use in the center stack of vehicles—the core dashboard area from which drivers control things like interior climate, audio, and navigation. Nartron filed suit against Futaba alleging patent infringement and copyright infringement. The complaint alleges that Futaba infringed on Nartron’s copyright for its PCBA software code and that Futaba infringed upon three of Nartron’s patents. The PCBAs were used in certain Dodge and Chrysler vehicles sold by Stellantis. The complaint alleges that Futaba used information from JVIS USA, LLC (“JVIS”), a nonparty and electronic parts manufacturer, to reverse engineer each and every aspect of Nartron’s PCBA. Futaba moved to dismiss, arguing that issue preclusion, also known as collateral estoppel, bars the patent infringement claims and that the copyright infringement claims are beyond the statute of limitations.

Patent infringement. The court held that collateral estoppel does not bar the patent infringement claims. Collateral estoppel applies when an issue has been actually litigated and determined by a valid and final judgment. At no point did any state court order determine that Futaba or JVIS owned the intellectual property disputed here. The federal district court gave no weight to a two-page final arbitration award, which presents simply a statement of the monetary damages awarded to JVIS with no findings, explanation, or reasoning. Because there may be multiple explanations for the arbitration outcome, collateral estoppel does not apply, the court found.

Furthermore, a federal court cannot simply transplant a state court’s finding as including the legal conclusions of the purely and exclusively federal issues before it. The claims here involve patent infringement. Any state law claims and accompanying facts that were actually litigated and determined in the state court litigation are to be given preclusive effect. But the court found the only conclusively determined fact that might be relevant in this patent case is that JVIS owned the physical PCBAs at issue in the state court litigation. And this fact does not appear to prevent Nartron from obtaining the patents at issue here. Because the issue of who owned the intellectual property relating to the PCBAs was not conclusively determined in the prior Michigan state court case, the federal court denied the motion to dismiss the patent infringement claims.

Copyright infringement. The court also largely held that the copyright infringement claim can move forward. The Copyright Act imposes a three-year statute of limitations on claims of copyright infringement. Looking at the four corners of the complaint, there are no factual allegations that affirmatively show that the copyright claim is time barred. Nartron alleges that it is the sole author and exclusive owner, and that at no point did it sell or authorize the defendants to use the copyrighted material.

At the pleading stage, the court accepted as true that Nartron is the registered owner of the copyright at issue. The court granted the motion to dismiss the copyright infringement claim, in part, only at to acts of infringement occurring before November 21, 2021, or three years before the filing of the complaint. But the court otherwise denied the motion to dismiss the copyright infringement claim.

The Case is No. 2:24-cv-13104-SKD-CI.

Judge: DeClercq, S.

Attorneys: Lawrence M. Hadley (Glaser Weil Fink Howard Jordan & Shapiro LLP) for UUSI, LLC. Craig Dickinson (The Miller Law Firm, PC) for Futaba Corp. of America.

Companies: UUSI, LLC dba Nartron; Futaba Corporation of America; JVIS USA, LLC; Stellantis N.V.

Cases: Copyright Patent TechnologyInternet MichiganNews