• Nov 19 2018
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  • Category: CAFC Updates

Enplas appeals the district court’s summary judgment that claim 20 of Seoul Semiconductor Company, Ltd.’s (“SSC”) U.S. Patent No. 6,007,209 (relating to methods of backlighting display panels, particularly LED displays used in televisions, laptop computers, and other electronics) is not anticipated. Following a jury trial on the remaining infringement and invalidity issues, Enplas also appeals: the district court’s denial of judgment as a matter of law (“JMOL”) that SSC’s U.S. Patent No. 6,473,554 is anticipated; denial of JMOL of no induced infringement; and denial of JMOL that the jury’s damages award is excessive and not supported by the trial evidence. The CAFCaffirms the judgment that the claims are not anticipated because at most, the testimony suggests that the prior art could have been modified to include certain features rather than disclosing each and every element of the claimed invention in a single reference.  The CAFC further affirms the district court’s finding of inducement because the evidence, while not overwhelming, provides at least circumstantial evidence that would allow a jury to reasonably find that Enplas had knowledge of the patents and of its customers’ infringing activity and that it intended to induce their infringement.   However, the CAFC vacates and remands with respect to the $4 million damages award for infringement of the ’554 patent, finding that the only evidence presented at trial to support a damages award above $570,000 was SSC’s expert’s damages theory applying a royalty to lenses that were neither accused of infringement nor shown to infringe. Judge Newman concurs with respect to validity and inducement and dissentswith respect to reversal of the jury’s damages verdict.

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