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## Overview Indect USA Corp. v. Park Assist, LLC is a patent infringement case involving methods of managing parking lot systems, decided on appeal by the U.S. Court of Appeals for the Federal Circuit (CAFC) (IPWatchdog, January 7). ## Background The case originated in the U.S. District Court for the Southern District of California and involved allegations of patent infringement over parking lot management technology, including a system used by a regional airport (IPWatchdog, January 7). ## The Ruling The Federal Circuit largely affirmed the district court's decision but reversed certain aspects after finding an abuse of discretion. Specifically, the court found the district court had improperly excluded evidence related to (1) invalidating sales of the patented method, and (2) bad-faith patent infringement allegations made against several customers of the accused infringer, including the regional airport customer (IPWatchdog, January 7). The case was vacated in part and appears headed back to the district court on the excluded-evidence issues. ## Why It Matters This ruling is notable for patent litigators because it addresses two recurring evidentiary issues in patent cases: (1) the admissibility of sales evidence for invalidity purposes (on-sale bar / prior commercial activity), and (2) evidence of bad-faith litigation conduct against downstream customers, which can be relevant to damages, willfulness, or unclean-hands-type defenses. CAFC guidance on evidentiary abuse-of-discretion standards is closely watched by patent practitioners because it shapes trial strategy in parallel litigation across the country. ## Track Going Forward - Remand proceedings at the Southern District of California - Potential settlement or retrial on the excluded evidence issues - Citation of this ruling in other CAFC evidentiary disputes