The court granted in part defendant's motion for judgment as a matter of law and reduced the jury's lump-sum royalty award of $70 million to $26.3 million where plaintiff's patent covered a small component within defendant's program that did not have a stand-alone market. "Although a reasonable royalty analysis 'necessarily involves an element of approximation and uncertainty,' it is the court’s duty 'to ensure that estimates are tied to . . . proper economic methodologies, not just numbers in an accounting format.' The Court concludes that no reasonable jury could conclude that Outlook within Office is worth $67, leaving the value of Word, Excel, and PowerPoint combined to be only $31. As a result, the Court concludes that the jury’s verdict is not supported by substantial evidence, and therefore, damages are excessive."
Lucent Technologies, Inc., et. al. v. Gateway, Inc., et. al., 3-07-cv-02000 (CASD November 10, 2011, Order) (Huff, J.)