After Halo, Jury Finding Alone Sufficient to Support Judgment of Willfulness

The court granted plaintiff's motion for judgment as a matter of law that defendants willfully infringed its transformer patent based on the jury's finding of willful infringement. "[T]he jury returned a verdict in favor of the Plaintiff, finding that [defendants] both acted willfully . . . . The Court deferred entering a judgment on the jury’s verdict, however, in order to consider the objective prong of the [In re Seagate Tech., LLC, 497 F.3d 1370 (Fed. Cir. 2007)] willfulness analysis. . . . [I]n [Halo Electronics, Inc. v. Pulse Electronics, Inc., 136 S. Ct. 1923 (2016)], the Supreme Court has overruled the objective prong of Seagate, leaving the issue of willfulness as solely a factual issue which can readily be addressed by a jury. Here, the jury was instructed to make a factual determination as to whether [defendants] acted willfully, and the jury answered this question in the affirmative. In light of Halo, this finding standing alone is sufficient to support a finding of willfulness. Because this Court is no longer required to make a finding to satisfy the 'objective recklessness' prong of Seagate, a judgment will therefore be entered based on the jury’s verdict that [defendants] willfully infringed the [patent-in-suit]."

Sociedad Espanola De Electromedicina Y Calidad, S.A. et al v. Blue Ridge X-Ray Company, Inc. et al, 1-10-cv-00159 (NCWD July 8, 2016, Order) (Reidinger, J.)