North Carolina Middle District Court

The United States District Court for the Middle District of North Carolina (M.D.N.C.) operates within the Fourth Circuit and maintains its headquarters in Greensboro, with additional offices in Winston-Salem and Durham. The MDNC handles a moderate number of patent cases, ranking 39th out of 94 federal district courts in patent filings between 2019 and 2022, placing it in the top 50% of U.S. jurisdictions for patent litigation.

While not characterized as a "rocket docket" in the same vein as some other high-volume patent courts, North Carolina federal district courts generally resolve cases slightly more quickly than several jurisdictions with higher patent caseloads. The MDNC has established Local Patent Rules (LPRs) designed to streamline the resolution of patent disputes, indicating an institutional commitment to efficiency. The court's practice on claim construction follows a structured process, similar to the Eastern District of Texas, outlining specific requirements for infringement and invalidity contentions, and facilitating Markman hearings as needed. Information on the court's track record concerning transfer motions or a consistent reputation as plaintiff- or defendant-friendly is not readily available through public statistics.

The MDNC's Local Patent Rules, effective February 8, 2021, are a distinctive feature of its patent litigation practice. These LPRs provide detailed procedures and deadlines for various stages of patent cases, including initial disclosures, preliminary and final infringement and invalidity contentions, and the claim construction process. Unlike the Eastern District of Texas, the MDNC's LPRs do not mandate the submission of a claim construction chart identifying disputed terms. Additionally, cases in the MDNC may involve the North Carolina Abusive Patent Assertions Act (APAA), a state law enacted in 2014 to combat "bad-faith assertion of patent infringement" by "patent trolls."

One prominent patent case currently tracked in the MDNC is Fullthrottle Technologies, LLC v. Rocket Media, LLC, filed on April 11, 2024, alleging patent infringement under 35 U.S.C. § 271. An inter partes review (IPR) related to this case, concerning U.S. Patent No. 11,556,947, was also initiated before the Patent Trial and Appeal Board. A noteworthy ruling from the MDNC occurred in NAPCO, Inc. v. Landmark Technology A, LLC, where the court, in August 2021, denied a motion to dismiss claims brought under the North Carolina APAA, affirming the act's constitutionality against challenges to free speech and equal protection.

Several judges are involved in patent litigation within the MDNC. District Judge William L. Osteen, Jr. is the presiding judge in Fullthrottle Technologies, LLC v. Rocket Media, LLC. District Judge Thomas D. Schroeder presided over the significant NAPCO, Inc. v. Landmark Technology A, LLC case. Chief District Judge Catherine C. Eagles leads the court. Magistrate Judge Joi Elizabeth Peake is the referring judge in the Fullthrottle Technologies case, and Magistrate Judge JoAnna Gibson McFadden chairs the court's Local Patent Rules Committee.