## Facts

- Aura Lamp & Lighting, Inc. filed a six-count federal action against International Trading Corp. involving business dealings over lighting products and components.
- Five counts alleged breach of contract; one count sought to invalidate a patent held by International Trading Corp.
- The district court ordered Aura Lamp to amend its complaint by a set deadline to cure diversity-jurisdiction pleading defects; Aura Lamp missed the deadline.
- The district court set briefing deadlines on International Trading Corp.’s motion to dismiss or transfer; Aura Lamp again missed a court-ordered deadline.
- During discovery, Aura Lamp failed to respond timely to interrogatories, document requests, and requests for admission, even after extensions.
- International Trading Corp. moved to compel, to deem admissions admitted, and for sanctions.
- The district judge warned that dismissal would be considered if deadlines were missed and permitted Aura Lamp to propose a discovery deadline; Aura Lamp still produced no documents and gave incomplete responses.
- The district court dismissed the action for want of prosecution and failure to comply with discovery orders under Rule 41(b) and the court’s inherent authority.
- Aura Lamp appealed to the Seventh Circuit; the appellee raised concern at oral argument that the appeal belonged in the Federal Circuit because the complaint included a patent-invalidity claim.

## Issues

1. Whether appellate jurisdiction lay exclusively in the Federal Circuit under 28 U.S.C. § 1295(a) because the district court’s jurisdiction was based in part on 28 U.S.C. § 1338 due to the patent-invalidity claim.
2. If the Seventh Circuit lacked jurisdiction, whether it should transfer the appeal under 28 U.S.C. § 1631 or dismiss it as futile.

## Decision

- The Seventh Circuit held it lacked appellate jurisdiction because the case included a claim arising under the patent laws, triggering exclusive Federal Circuit jurisdiction under 28 U.S.C. § 1295(a).
- The court dismissed the appeal rather than transfer it, concluding transfer was not in the interest of justice because the appeal was substantively meritless (“doomed”).
- The district court’s dismissal for want of prosecution and discovery noncompliance remained in effect.

## Legal Principles

- Under 28 U.S.C. § 1295(a), the Federal Circuit has exclusive jurisdiction over an appeal from a final district-court decision when the district court’s jurisdiction was based in whole or in part on 28 U.S.C. § 1338.
- A claim seeking to invalidate a patent arises under the patent laws for purposes of § 1338 and can determine exclusive appellate routing, even when other claims sound in contract.
- Under 28 U.S.C. § 1631, a court may decline to transfer a misfiled appeal when transfer would be futile and thus not in the interest of justice.
- A district court may dismiss an action under Rule 41(b) and its inherent authority for repeated noncompliance with court orders and discovery obligations, especially after warnings and opportunities to cure.

## Conclusion

The Seventh Circuit concluded that the patent-invalidity claim placed the appeal within the Federal Circuit’s exclusive jurisdiction and dismissed, rather than transferred, the misdirected appeal because the record of repeated missed deadlines and discovery failures made reversal unrealistic.


Aura Lamp & Lighting, Inc. v. Int’l Trading Corp., 325 F.3d 903 (7th Cir. 2003)