Narrative Opinion Summary
This case involves a dispute between two corporations over the willful infringement of U.S. Patents No. 6,558,194 and No. 6,848,940. After a jury trial in July 2015, the defendant was found to have willfully infringed the patents, leading to a substantial damages award. The defendant sought judgment as a matter of law or a new trial, challenging the jury's findings on several grounds, including improper jury instructions on the doctrine of equivalents and the sufficiency of evidence for infringement. The court denied these motions, affirming the jury's verdict and finding adequate evidence of infringement, both literally and under the doctrine of equivalents. The defendant also pursued an inequitable conduct defense, alleging that the plaintiff's failure to disclose certain information during patent reexaminations constituted deceit. However, the court granted summary judgment to the plaintiff on this defense, emphasizing the absence of clear and convincing evidence of intent to deceive the PTO. The court further addressed various defenses and procedural issues, ultimately rejecting the defendant's arguments for a new trial or remittitur of the damages award, and upheld the jury's decision. The court reserved additional matters for a bench trial, including outstanding equitable defenses.
Legal Issues Addressed
Doctrine of Equivalents and Prosecution History Estoppelsubscribe to see similar legal issues
Application: The court upheld the jury's instruction on the doctrine of equivalents, rejecting Corning's argument of prosecution history estoppel.
Reasoning: Corning asserts that the jury should not have received instructions on the doctrine of equivalents due to prosecution history estoppel, which PPC counters by claiming that Corning waived objections to the verdict form.
Enhanced Damages for Willful Infringement Post-Halo Electronicssubscribe to see similar legal issues
Application: The court considered subjective willfulness and granted enhanced damages based on the jury's findings of willful infringement under Halo Electronics.
Reasoning: The burden of proof was also lowered from clear and convincing evidence to a preponderance of the evidence for establishing recklessness.
Inequitable Conduct in Patent Lawsubscribe to see similar legal issues
Application: Corning's defense of inequitable conduct was dismissed as it failed to meet the required standards of proving intent to deceive the PTO.
Reasoning: Corning's claims against PPC regarding inequitable conduct do not meet the stringent standards set by Therasense.
Judgment as a Matter of Law under Rule 50subscribe to see similar legal issues
Application: Corning's motion for judgment as a matter of law was denied as the evidence was sufficient for a reasonable jury to find in favor of PPC.
Reasoning: Under Rule 50, a judgment as a matter of law is warranted when a party has been fully heard and lacks a sufficient evidentiary basis for a jury's favorable finding.
New Trial under Rule 59subscribe to see similar legal issues
Application: Corning's request for a new trial was denied since the jury's verdict was not found to be seriously erroneous or a miscarriage of justice.
Reasoning: Conversely, Rule 59 allows for a new trial if the jury's verdict is deemed seriously erroneous or a miscarriage of justice.
Patent Validity and Collateral Estoppelsubscribe to see similar legal issues
Application: The court previously determined the validity of the 194 patent via collateral estoppel, leading Corning to abandon its patent validity challenges.
Reasoning: Previously, the court had ruled the 194 patent valid via collateral estoppel, leading Corning to abandon its challenge on the validity of the 940 patent.
Summary Judgment on Inequitable Conduct Defensesubscribe to see similar legal issues
Application: The court granted PPC's motion for summary judgment dismissing Corning's inequitable conduct defense for lack of clear and convincing evidence of deceptive intent.
Reasoning: Consequently, the court granted summary judgment to PPC and dismissed Corning's counterclaim of inequitable conduct.
Willful Patent Infringementsubscribe to see similar legal issues
Application: Corning was found to have willfully infringed PPC's U.S. Patents No. 6,558,194 and No. 6,848,940, which justified the jury's award of enhanced damages.
Reasoning: Following a jury trial in July 2015, Corning Optical Communications RF, LLC was found to have willfully infringed PPC Broadband, Inc.'s U.S. Patents No. 6,558,194 and No. 6,848,940.