When it comes to litigation, plaintiffs often prefer federal courts because cases tend to move faster than in state courts. But what happens when federal law works against them, forcing their case into a swift dismissal? That’s exactly what happened in BearBox LLC v. Lancium LLC, where the Federal Circuit not only shut down a state law conversion (theft) claim but also rejected an inventorship challenge—all thanks to the power of federal preemption and strict evidentiary standards.
The Case at a Glance
This dispute began with a chance meeting at a Bitcoin mining conference in 2019. After a brief conversation and a follow-up email, BearBox’s founder, Austin Storms, shared details about the company’s technology with Lancium’s co-founder. Five months later, Lancium filed a patent application, which ultimately became U.S. Patent No. 10,608,433.
BearBox sued, claiming:
- Correction of inventorship (arguing that Storms should be named as an inventor under federal patent law).
- Conversion under Louisiana state law (essentially arguing that Lancium “stole” BearBox’s technology).
The problem? Federal patent law preempted BearBox’s state law claim, and the inventorship argument collapsed under strict evidentiary rules.
Why Federal Preemption Matters
While state law conversion claims aren’t always preempted, the court found that BearBox’s claim too closely resembled a patent infringement case. The ruling emphasized a key legal principle:
State law cannot be used to give “patent-like” protection to ideas that are not patented or protected as trade secrets.
BearBox had shared its technology without restrictions—meaning it couldn’t later claim exclusive rights under state law. The Federal Circuit relied on Bonito Boats, Inc. v. Thunder Craft Boats, Inc., a Supreme Court case that reinforced the importance of free public access to unpatented ideas.
Why Federal Courts Move Faster—and Why That Worked Against BearBox
Plaintiffs often prefer federal courts because cases move more quickly than in state courts. However, this speed can also work against weaker claims, as shown in BearBox LLC v. Lancium LLC:
- Federal Preemption Eliminated the State Claim Early – BearBox’s attempt to bring a state law claim failed because the Federal Circuit ruled that patent law preempted it, cutting the case short.
- Strict Evidentiary Standards Doomed the Inventorship Claim – To prove inventorship, BearBox needed clear and convincing evidence, including independent corroboration. The court found its evidence—mainly a single email with attachments—insufficient.
- Summary Judgment Streamlined the Case – Rather than dragging on for years, the district court granted summary judgment, meaning BearBox’s claims never even made it to trial.
- Appellate Review Was Quick and Decisive – The Federal Circuit affirmed the ruling without remanding, reinforcing how federal courts efficiently dispose of meritless claims.
The Takeaway: Federal Court Speed Cuts Both Ways
Plaintiffs often seek out federal court for faster resolutions, but BearBox is a cautionary tale:
✅ If you have strong claims, federal court can move your case forward quickly.
❌ If your claims are weak, federal court will cut them down just as fast.
For those in intellectual property disputes, this case underscores the importance of securing patent protection or trade secret safeguards before sharing valuable technology. Otherwise, you might find yourself on the wrong end of federal preemption—watching your case disappear at lightning speed.