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OPTi, Inc. v. VIA Technologies, Inc.

Citations: 65 F. Supp. 3d 465; 2014 U.S. Dist. LEXIS 120695; 2014 WL 4292084Docket: CASE NO. 2:10-CV-00279-JRG

Court: District Court, E.D. Texas; August 29, 2014; Federal District Court

Narrative Opinion Summary

In this patent infringement case, OPTi, Inc. sued VIA Technologies, Inc. for infringing U.S. Patent No. 5,710,906, known as the 'Pre-Snoop Patent,' which optimizes data transfer efficiency in computer systems. The jury found VIA liable for direct and indirect infringement of claim 26, awarding $2,111,905.40 in damages. VIA's defenses, including claims of anticipation, indefiniteness, and lack of enablement under 35 U.S.C. § 112, were rejected, affirming the patent's validity. The court denied VIA's post-trial motions for judgment as a matter of law (JMOL) and a new trial, citing substantial evidence supporting the jury's findings. VIA was also found liable for induced infringement despite contending a good-faith belief in the patent's invalidity. The court maintained its prior claim construction and dismissed VIA's challenge to the jury instructions. Ultimately, all of VIA's motions were denied, upholding the jury's verdict, and solidifying OPTi’s position in the litigation.

Legal Issues Addressed

Induced Infringement

Application: The jury found VIA liable for induced infringement based on evidence of marketing infringing features and customer use, despite VIA's argument of a good-faith belief in patent invalidity.

Reasoning: The jury was tasked with evaluating whether VIA held a good-faith belief in the invalidity of the '906 Patent regarding OPTi’s induced infringement claim, yet ultimately found VIA liable for induced infringement.

Judgment as a Matter of Law (JMOL) Standards

Application: VIA's motions for JMOL were denied as the evidence presented was sufficient to support the jury's verdict on patent infringement and validity.

Reasoning: The standards for JMOL require that a reasonable jury must have sufficient evidence to support its findings, with a high threshold for overturning a jury's verdict.

Patent Claim Construction

Application: The court upheld its previous construction of the term 'constant rate' and denied VIA's motion for a new trial based on claim construction arguments.

Reasoning: Regarding claim construction, the Court rejected VIA's proposed definition of 'constant rate,' reaffirming its previous construction, thus denying VIA’s motion for a new trial based on this argument.

Patent Infringement Liability

Application: VIA Technologies, Inc. was found liable for both direct and indirect infringement of claim 26 of the '906 Patent, with a jury awarding damages of $2,111,905.40.

Reasoning: A trial concerning the '906 Patent commenced on May 28, 2013, resulting in a jury verdict that found VIA liable for both direct and indirect infringement of claim 26 of the '906 Patent.

Patent Validity Presumption

Application: OPTi successfully defended the validity of the '906 Patent against VIA's claims of anticipation, indefiniteness, and lack of enablement, with the jury finding the patent valid.

Reasoning: The jury's decision to accept OPTi's position is supported by substantial evidence, affirming the validity of the '906 Patent.