This morning, the Federal Circuit issued precedential opinions in two patent cases, the first addressing infringement, enablement, damages, and willfulness, and the second addressing sanctions. The court also issued a nonprecedential opinion in another patent case, this opinion addressing motions to exclude expert testimony. Here are the introductions to the opinions.
Bayer HealthCare LLC v. Baxalta Inc. (Precedential)
This patent infringement case presents various issues of claim scope, infringement, validity, and damages. Bayer HealthCare LLC sued Baxalta Inc. and Baxalta US Inc. (collectively, “Baxalta”) and Nektar Therapeutics, alleging that Baxalta’s biologic product Adynovate® infringes certain claims of Bayer’s U.S. Patent No. 9,364,520. The jury found that the asserted claims were enabled and infringed, and that Bayer was entitled to reasonable-royalty damages. The district court did not, however, send the question of willful infringement to the jury, instead holding as a matter of law that Baxalta’s conduct did not meet the requirements for willfulness. Baxalta now appeals the district court’s denial of its motions for judgment as a matter of law or a new trial on the issues of infringement, enablement, and damages, along with the court’s award of pre-verdict supplemental damages. Bayer cross-appeals, challenging the district court’s denial of its motion for a new trial on willfulness. We affirm.
Arunachalam v. International Business Machines Corp. (Precedential)
Appellant, Dr. Lakshmi Arunachalam, appeals from three decisions of the U.S. District Court for the District of Delaware (“District Court”): two granting-in-part and denying-in-part attorneys’ fees to Appellees, SAP America, Inc. (“SAP”), JPMorgan Chase & Co. (“JPMorgan”), and International Business Machines Corp. (“IBM”), see Arunachalam v. Int’l Bus. Machines Corp. (Arunachalam I), No. CV 16-281-RGA, 2019 WL 1388625, at *2 (D. Del. Mar. 27, 2019) (Memorandum); C.A. 11 (Order); Arunachalam v. Int’l Bus. Machines Corp. (Arunachalam II), No. CV 16-281-RGA, 2019 WL 5896544, at *3 (D. Del. Nov. 12, 2019) (Memorandum); C.A. 3–4 (Order); and one denying two of Dr. Arunachalam’s additional motions, C.A. 1–2 (Order Denying Motions to ‘Enforce the Mandated Prohibition’ and to Vacate Its ‘Unconstitutional Order’). The District Court explained that Dr. Arunachalam’s “abusive” litigation conduct warranted monetary sanctions, Arunachalam I, 2019 WL 1388625, at *2; see Arunachalam II, 2019 WL 5896544, at *1, and that her two later-filed motions were baseless and untimely, C.A. 2. We have jurisdiction pursuant to 28 U.S.C. § 1295(a)(1). We affirm.
Finalrod IP, LLC v. John Crane, Inc. (Nonprecedential)
Plaintiffs-Appellants Finalrod IP, LLC and R2R and D, LLC, dba Superod (collectively, “Superod”) sued Defendants-Appellees John Crane, Inc., John Crane Production Solutions, Inc., and Endurance Lift Solutions Inc. (collectively, “John Crane”) for patent infringement. Superod alleged that John Crane’s Series 200 end fitting (“S200”) and Series 300 end fitting (“S300”) each infringe U.S. Patent Nos. 9,045,951 and 9,181,757. The district court granted two Daubert motions filed by John Crane: (1) a motion to exclude Mr. Hetmaniak, Superod’s technical expert, from testifying as to whether the S200 or S300 meets four of the disputed limitations (collectively, “the four limitations”)1 and as to whether the S300 meets the compressive-forces limitation; and (2) a motion to exclude Mr. Reading, one of Superod’s damages experts, from testifying as to reasonable royalty damages pertaining to the S300. In view of these rulings, the parties stipulated to a final judgment of noninfringement. See J.A. 1. This appeal followed. We have jurisdiction under 28 U.S.C. § 1295(a)(1).