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Lambda Research, Inc. v. Jacobs

Citation: 2013 Ohio 348Docket: C-100796

Court: Ohio Court of Appeals; February 5, 2013; Ohio; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves an appeal by Jacobs against a judgment in favor of his former employers, Lambda Research Inc. and Surface Enhancement Technologies LLC, following a jury trial. Jacobs challenged the trial court's denial of his motions for judgment notwithstanding the verdict and a new trial, arguing that Lambda failed to establish causation for its claims, including tortious interference and breach of contract. The appellate court upheld the trial court's decision, citing sufficient evidence supporting the jury's findings and the propriety of admitting speculative testimony. Jacobs's objections to expert testimony were waived due to lack of timely objection, and his contention regarding improper service under the Hague Services Convention was dismissed since it pertained to a co-defendant who had settled. Further, Jacobs's appeal concerning arbitration was deemed waived due to his failure to timely contest the trial court's order and continued litigation. The court also affirmed the attorney fee award to Lambda, as Jacobs did not provide evidence to allocate fees among claims. Consequently, the judgment against Jacobs was sustained as the trial court did not err in its rulings on these issues.

Legal Issues Addressed

Attorney Fees and Claims Separation

Application: The court upheld the fee award as Jacobs did not provide evidence to counter the testimony that fees could not be separated by claim.

Reasoning: Consequently, the court found no abuse of discretion in the trial court's fee award and affirmed the judgment.

Expert Testimony and Objections

Application: Jacobs's failure to object to the expert's qualifications during the trial precluded addressing errors related to the testimony.

Reasoning: Jacobs's lack of objection during the trial precluded the court from addressing any errors related to Long's testimony.

Judgment Notwithstanding the Verdict and Motion for New Trial

Application: The court upheld the trial court's denial of Jacobs's motions because reasonable evidence supported the jury's conclusions.

Reasoning: The court, applying a standard that favors Lambda, determines that reasonable evidence supported the jury's conclusions regarding Jacobs's interference and breaches, thus upholding the denial of his motions.

Misappropriation-of-Trade-Secrets Claim and Damages

Application: The court found no abuse of discretion in the denial of remittitur as the damage award was supported by evidence.

Reasoning: The court found no plain error in Long's testimony and did not abuse its discretion in denying Jacobs's motion for remittitur of damages on the misappropriation-of-trade-secrets claim, as the jury’s damage award was not excessive and was supported by the evidence.

Service of Process under Hague Services Convention

Application: The trial court's denial of Jacobs's motion to vacate the judgment based on service issues was upheld as the issue was personal to Ecoroll AG.

Reasoning: Jacobs incorrectly cited O.B. Corp. v. Cordell and Rondy v. Rondy to support his argument that a judgment against him was void due to service issues involving a co-defendant.

Waiver of Right to Appeal Arbitration Ruling

Application: Jacobs waived his right to appeal the arbitration ruling by failing to appeal the trial court's order and proceeding with litigation.

Reasoning: By failing to do so and engaging in extended litigation, including a three-week jury trial, Jacobs waived his right to contest the trial court's arbitration ruling.