COLUMBIA SPORTSWEAR v. SEIRUS INNOVATIVE ACCESSORIES
- Nov 13 2019 |
- Category: CAFC Updates
Columbia Sportswear appeals from the District Court’s judgment after a jury trial that certain claims of U.S. Patent 8,453,270 (relating to materials that use a pattern of heat-directing elements coupled to a base fabric to manage heat through reflection or conductivity) are invalid as anticipated and obvious. Seirus cross-appeals from the District Court’s grant of summary judgment that it infringes U.S. Patent D657,093 (drawn to the ornamental design of a heat reflective material) and from its entry of the jury’s damages award. The CAFC concludes that the jury’s obviousness verdict was supported by substantial evidence (including that expert testimony presented was not intentionally false testimony) and therefore the District Court did not err in holding the claims of the ’270 patent invalid. The CAFC further finds, however, that it did err in granting summary judgment of infringement for the ’093 patent for two reasons: (1) the District Court improperly declined to consider the effect of Seirus’s logo in its infringement analysis and (2) the District Court resolved a series of disputed fact issues, in some instances relying on an incorrect standard, that should have been tried to a jury. Accordingly, the CAFC affirms-in-part, reverses-in-part, and remands.