Serby v. First Alert, Inc.
Plaintiff Victor M. Serby, an attorney proceeding pro se, brought this action against First Alert, Inc. and BRK Brands, Inc. for breach of a pre-existing settlement agreement. Serby alleged the Defendants failed to pay royalties for smoke detectors incorporating his '434 Patent, stemming from a prior patent infringement litigation. Defendants countered that their new SA340 model smoke alarm did not meet the 'unopenable' condition of the settlement agreement, thus absolving them of royalty payments. Serby moved for summary judgment and to strike Defendants' affirmative defenses, arguing that the doctrines of res judicata and collateral estoppel barred these defenses due to the previous litigation and settlement. The Court denied Serby's motion in its entirety, finding that genuine issues of material fact existed regarding the similarity of the smoke alarm models and that neither res judicata, collateral estoppel, nor contractual estoppel applied. Furthermore, the Court determined that the heightened pleading standards of Bell Atl. Corp. v. Twombly do not extend to affirmative defenses.