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Emma Schultz is an associate attorney in our litigation group. She focuses her practice on research, strategy, case development, and appellate work.

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Emma Schultz is an associate attorney in our litigation group. She focuses her practice on research, strategy, case development, and appellate work.

Emma has supported matters involving civil rights, ERISA litigation, and False Claims Act investigations. She previously served as a law clerk at the Minnesota Court of Appeals, assisting with legal research, opinion preparation, and detailed analysis. Emma also worked with local businesses in Boston College Law School’s Entrepreneurship and Innovation Clinic, helping them lay strong foundations through formation planning, compliance guidance, and carefully crafted contracts.

Emma has supported matters involving civil rights, ERISA litigation, and False Claims Act investigations. She previously served as a law clerk at the Minnesota Court of Appeals, assisting with legal research, opinion preparation, and detailed analysis. Emma also worked with local businesses in Boston College Law School’s Entrepreneurship and Innovation Clinic, helping them lay strong foundations through formation planning, compliance guidance, and carefully crafted contracts.

She earned her J.D. from Boston College Law School, completing the Public Interest Designation Program and receiving a Certificate of Pro Bono Excellence in recognition of her dedication to service. Before law school, Emma studied Chemistry at Northwestern University – an analytical foundation she brings to her litigation work, examining each problem carefully and methodically to help chart the best path forward.

She earned her J.D. from Boston College Law School, completing the Public Interest Designation Program and receiving a Certificate of Pro Bono Excellence in recognition of her dedication to service. Before law school, Emma studied Chemistry at Northwestern University – an analytical foundation she brings to her litigation work, examining each problem carefully and methodically to help chart the best path forward.

Boston College Law School, J.D., 2024

Northwestern University, B.A. Chemistry, 2021

Minneapolis

Last week, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion in <a href="https://www.cafc.uscourts.gov/opinions-orders/24-1039.OPINION.9-24-2025_2577864.pdf">Finesse Wireless LLC v. AT&T Mobility LLC, No. 24-1039 (Sept. 24, 2025)</a>, reversing the district court’s denial of judgment as a matter of law (JMOL) of noninfringement and vacating the jury’s award of over $160 million in damages.



Finesse sued AT&T for infringement of two patents relating to methods of reducing interference in radios. Finesse’s first patent claims a method of reducing intermodulation product (IMP) interference by sampling “signals of interest” and “interference generating signals,” isolating the two signal types, and cancelling out the interference generating signals. Finesse’s second patent claims a method of reducing IMP interference by creating IMP cancellation signals through seven digital multiplications of three signals.



At trial, regarding the first patent, Finesse’s infringement expert testified that he mapped the signals of interest to a downlink transmit reference and mapped the interference generating signals to a modeled passive intermodulation products (PIM) path. The expert later changed his testimony to identify “x1” and “x2” but did not explicitly map “x1” and “x2” to the signals of interest and interference generating signals. Regarding the second patent, Finesse’s expert testified that the accused radios performs the claims multiplications but relied on a document identifying only three multiplications.



AT&T moved for JMOL. The district court denied the motion, ruling for the first patent that there was sufficient evidence that the accused radios’ receivers sample both the “signals of interest” and “interference generating signals” and therefore infringe Finesse’s patent. For the second patent, the district court denied JMOL in part because the three multiplications corresponded to some of the seven claimed multiplications.



The Federal Circuit reversed. On the first patent, the Court reversed because the expert testimony was unclear. The Court held that even if the expert mapped x1 and x2 to the signals of interest and interference generating signals, he did not explain his contradictory testimony, and his testimony was insufficient to support the jury’s verdict. On the second patent, the Court reversed because neither the expert nor the document indicated how the three multiplications mapped onto the seven multiplications. Therefore, no reasonable jury could have found that the accused radios practiced the seven claimed multiplications.

CAFC Reverses District Court Denial of JMOL in Radio Interference Patent Case

Last week, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion in <a href="https://www.cafc.uscourts.gov/opinions-orders/24-1707.OPINION.9-2-2026_2749527.pdf" data-type="link" data-id="https://www.cafc.uscourts.gov/opinions-orders/24-1707.OPINION.9-2-2026_2749527.pdf">Netlist, Inc. v. Micron Technology, Inc., No. 2024-1707 (Sept. 2, 2026)</a>, affirming the Patent Trial and Appeal Board’s final written decision that all challenged claims of U.S. Patent No. 10,949,339 (the “’339 Patent”) are unpatentable as obvious.



Netlist’s ’339 Patent relates to computer memory systems using buffers between a memory controller and DRAM devices. The buffers have data paths that are generally disabled to isolate the DRAM devices but are selectively enabled during read or write operations to drive the data signal.



Micron and Samsung Electronics Co., Ltd. (“Samsung”) petitioned for inter partes review, arguing claims 1-35 of the ’339 Patent were unpatentable as obvious over the combination of U.S. Patent Application Publication No. 2006/0277355 (“Ellsberry”) and U.S. Patent No. 7,024,518 (“Halbert”). Representative claim 1 requires that a “data path” through the buffer is “enabled” at a certain time (“in accordance with a latency parameter”) for a certain duration (a “first time period”) so that a memory controller can drive write data through the buffer to the DRAM device.



The Board found all challenged claims obvious. Netlist appealed, arguing the Board erred by (1) determining Ellsberry teaches data paths enabled “in accordance with a latency parameter” and “enabl[ing]” a “data path,” and (2) violating the APA.



The Federal Circuit affirmed. On the latency parameter, the Court found substantial evidence supported the Board’s determination. Specifically, Ellsberry disclosed storing “Posted CAS_n” in the memory bank switch. The Court also rejected Netlist’s assertion that the Board improperly relied on Netlist’s U.S. Patent No. 7,532,537, which was not part of Samsung’s petition, noting any error was harmless because the Board found that Ellsberry alone teaches adding one clock cycle of latency to account for the buffers.



On “enabl[ing]” a “data path,” Netlist claimed that Ellsberry directly enables and disables memory banks outside the buffer rather than connecting and disconnecting data paths within it. The Court ruled substantial evidence supported the Board’s determination that Ellsberry’s Ports A and B are components within the switch ASIC and that enabling the ports constitutes enabling data paths. The Court also noted the Board’s alternative finding that the Ellsberry and Halbert combination teaches this limitation.



Finally, the Court rejected Netlist’s APA arguments, claiming that the Board adequately addressed Netlist’s arguments and that Netlist did not develop its other contentions on appeal.

Emma G. Schultz

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