Settlement Alone Does Not Justify Vacatur of Invalidity Finding

The court denied the parties' motion to vacate the court's earlier order granting defendant's motion for judgment on the pleadings that plaintiff's data processing patent was invalid because the parties had settled. "[T]he parties do not address any element of Rule 60(b). Rather, they simply indicate that vacatur is proper because it would 'serve the public interest since it facilitates a resolution of all the litigation between the parties and the dispute regarding this particular issue.' In other words, the public interest is served by the settlement of this action. This is insufficient. . . . The parties do not point to any 'extraordinary circumstance' that would warrant vacatur."

DATATRAK International, Inc. v. Medidata Solutions, Inc., 1-11-cv-00458 (OHND February 3, 2016, Order) (Gaughan, J.)