March 30, 2012 - District Judge Leonard P. Stark granted defendants’ motion for summary judgment of noninfringement of plaintiff St. Clair’s [NPE] patents that collectively describe an “electronic still camera” that “selectively formats the compressed digital image to a compatible format [for PCs and MACs],” in their specification (The ‘Roberts Patents’: 5,138,459, 6,094,219, 6,323,899, 6,233,010).  St. Clair’s asserted claims included a limitation to format an image in a plurality of different data formats.  Judge Stark’s decision to grant summary judgment was primarily based on a recent Federal Circuit determination that was decided in another one of St. Clair’s litigations involving the same patents, “that the claim limitations require a plurality of image formats.”  St. Clair did not dispute that the accused products in this case, with the exception of two, contained only a single data format.  Therefore, the Court granted summary judgment because, “the accused products are not capable of producing more than one still image format.”  The Court also denied St. Clair’s motion to supplement its experts reports with additional theories of infringement by stating that St. Clair, “was keenly aware of the possibility that [the appeal in the other case] may impact this case, yet it chose to proceed under its sole infringement theory…A strategic mistake does not equate to a showing of good cause under Rule 16.”