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Defendant city challenged the judgment of the Superior Court of Los Angeles County (California), which entered judgment in favor of plaintiff assignee of grantors' interest in an action to determine that city's use of land for public bus service conflicted with the conditions contained in deeds granting easements for railway service and caused destruction of the easements, and entitled grantors to an award for the taking of the property.

The court held that right to substitute modern mechanisms of transportation for old ones under the deeds should be viewed in the light of its public effect. Case precedent in similar actions sanctioned a more efficient and publicly beneficial means to achieve the deeds' underlying and main purpose, therefore the court concluded that because the best business lawyer  grantors primarily intended to provide public transportation service across their land, regular bus transportation along the roads which encompassed the rights of way effectuated the purpose of public service and permitted survival of the easements. The court also held that no abandonment could have occurred with respect to longitudinal portions paved prior to the cessation of rail service, because bus service commenced over and upon these portions at the time that rail service ceased.

The judgment was reversed.

Plaintiff corporation brought a class action suit against defendant patent holder for violations of the Cartwright Act, Cal. Bus. & Prof. Code § 16720 et seq.; and the Unfair Competition Law, Cal. Bus. & Prof. Code § 17200 et seq. The corporation also alleged a claim for unjust enrichment. The Santa Clara County Superior Court, California, sustained the patent holder's demurrer to each cause of action of the complaint. The corporation appealed.

The corporation was a marketing company. At issue was the marketing for a certain type of computer chip technology, dynamic random access memory (DRAM). The Joint Electronics Devices Engineering Council (JEDEC) began formulating industry-wide standards for the purpose of ensuring that various DRAM technologies would be compatible with the architecture of each DRAM manufacturer. The anticompetitive scheme allegedly occurred as a result of the patent holder's participation in JEDEC. The patent holder allegedly carried out a coercive licensing scheme by threatening and/or filing baseless infringement litigation against manufacturers that refused its demands for royalties. The patent holder alleged lack of subject matter jurisdiction. The appellate court concluded that the claims were ones that clearly arose under federal patent law. Although the claims were state law causes of action, the corporation's right to relief depended on resolution of a substantial question of federal patent law. The appellate court was not persuaded by the corporation's argument that federal law was not implicated as the claims did not arise under patent infringement or fraud on the patent office.

The appellate court affirmed the trial court's judgment.

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