Offer of Complete Relief Divested District Court of Jurisdiction

Samsung Electronics Co., Ltd., v. Rambus, Inc., [2006-1579] (April 29, 2008) The Federal Circuit vacated the order of the district court and remands the case to the district court with the instruction that it dismiss Samsung's declaratory judgment action.
BRIEF: To avoid an adverse finding of spoilation of evidence, RAMBUS granted a covenant not to sue, and offered Samsung its attorneys’ fees. Samsung rejected the offer, and the district court entered judgment finding the case exceptional, but denying Samsung its attorneys’ fees. On Appeal the Federal Circuit held that Rambus’ offer eliminated the controversy between the parties, divesting the district court of jurisdiction. Accordingly, the district court in this case lacked jurisdiction to issue any further opinions in conjunction with an attorney fees dispute that has ceased to exist. Because the district court's writing is an impermissible advisory opinion, the Federal Circuit vacated that advisory opinion as issued without jurisdiction. In sum, the offer of the full amount in dispute brought an end to the case and controversy between Rambus and Samsung. At that point the district court also lacked subject matter jurisdiction to rule on the attorney fees motion.