Qiang Wang v. Palo Alto Networks, Inc., 686 F. App'x 890

Background

Wang sued Palo Alto Networks (PAN) for patent inventorship, patent infringement, and trade secret misappropriation; trade secret claims were dismissed on summary judgment.
Counsel negotiated a "walk-away" settlement mediated by Magistrate Judge Ryu: each side would drop claims and PAN would not seek fees; Wang signed a settlement signature page on April 24, 2014, striking a clause in Paragraph 7 disavowing inventorship but leaving the rest intact.
Counsel substituted a clean final agreement reflecting Wang’s edit in substance, appended Wang’s signed page, all parties executed the final agreement, and the parties filed a joint stipulation dismissing all claims with prejudice that the district court granted.
That same evening Wang emailed the magistrate judge saying he signed under duress/while "insane" and later moved pro se to vacate the settlement, alleging coercion by his attorney, lack of capacity, and defects in the final agreement.
The district court denied Wang’s motion (noting counsel remained of record but principally concluding no viable ground to set aside the dismissal) and closed the case; Wang appealed and the appeal was transferred to the Federal Circuit.
The Federal Circuit treated Wang’s filing as a Rule 60(b) motion for relief from judgment and affirmed, holding Wang failed to show grounds for relief (e.g., mistake excusing signing, fraud by the opposing party, or extraordinary circumstances).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the voluntary dismissal/settlement can be vacated under Rule 60(b)(1) for mistake/excusable neglect	Wang says he signed under duress/while "insane" and counsel pressured him into signing	PAN says Wang knowingly executed the settlement and counsel had authority to file dismissal	Denied — Rule 60(b)(1) does not relieve a party for regretted litigation decisions or counsel advice; no evidence Wang lacked understanding
Whether relief is available under Rule 60(b)(3) for fraud/misrepresentation by adverse party	Wang alleges coercion by his own attorney, not misconduct by PAN	PAN emphasizes Rule 60(b)(3) requires misconduct by the opposing party	Denied — no allegation or proof of misconduct by PAN; rule requires adverse-party misconduct
Whether Rule 60(b)(6) equitable relief applies to prevent manifest injustice	Wang argues attorney misconduct and procedural defects in the executed agreement justify relief	PAN argues no extraordinary circumstances prevented timely action; settlement was substantively accepted	Denied — no extraordinary circumstances shown to warrant the rare equitable remedy
Whether counsel lacked authority to settle/dismiss due to defects in the agreement	Wang points to physical edits, multiple signature pages, and nonidentical paragraph text	PAN notes Wang signed a settlement substantively identical to executed version and counsel had apparent authority	Denied — record shows Wang agreed to and signed the settlement; district court did not abuse discretion

Key Cases Cited

Latshaw v. Trainer Wortham & Co., 452 F.3d 1097 (9th Cir. 2006) (party bound by litigation decisions despite attorney misconduct or poor advice; Rule 60(b)(1) not a remedy for regretted counsel-based decisions)
Duke Energy Trading & Mktg., L.L.C. v. Davis, 267 F.3d 1042 (9th Cir. 2001) (dismissal by notice/stipulation divests district court of jurisdiction over dismissed claims)
Venture Indus. Corp. v. Autoliv ASP, Inc., 457 F.3d 1322 (Fed. Cir. 2006) (appellate jurisdiction principles relevant to transferred appeals)
Harrop v. W. Airlines, Inc., 550 F.2d 1143 (9th Cir. 1977) (where plaintiffs agreed to settle or attorneys had authority, district court may deny motion to set aside dismissal)
In re Hunter, 66 F.3d 1002 (9th Cir. 1995) (pro se filings construed liberally; post-judgment motions may be treated under Rule 60(b))
Lazare Kaplan Int’l, Inc. v. Photoscribe Techs., Inc., 714 F.3d 1289 (Fed. Cir. 2013) (procedural Rule 60(b) issues defer to regional circuit law)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se submissions are liberally construed)