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.)
Tuesday, July 12, 2016
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]."