This morning, the Federal Circuit released one nonprecedential opinion. It addresses a challenge to the denial of monetary and injunctive relief after a jury determination of willful infringement in a patent case. Here is the introduction to the opinion.
In re California Expanded Metal Products Co. (Nonprecedential Opinion)
California Expanded Metal Products Co. (CEMCO) owns several patents that describe and claim fire-retardant head-of-wall assemblies. In 2020, Seal4Safti, Inc. filed an action in district court seeking a declaratory judgment of noninfringement, unenforceability, and invalidity of several of those patents, and CEMCO filed affirmative defenses and counterclaims for patent infringement. In a 2022 trial, a jury determined that Seal4Safti had willfully induced infringement of all asserted patent claims and awarded CEMCO damages in the form of a reasonable royalty. J.A. 1267–69. Subsequently, the district court denied CEMCO’s request for a permanent injunction, J.A. 50–52, and set aside the jury’s damages award on the ground that CEMCO did not meet its burden to prove the amount of a reasonable royalty, Seal4Safti, Inc. v. California Expanded Metal Products Co., No. 20-cv-10409, 2022 WL 16710721, at *3–4 (C.D. Cal. Oct. 3, 2022) (Post-Trial Order); see also id. at *5–6 (finding case exceptional and declaring CEMCO entitled to attorney’s fees). The court entered judgment for CEMCO on all its claims and against Seal4Safti on all its claims, but awarded “no monetary or injunctive relief.” J.A. 1200.
On appeal, CEMCO challenges the denial of monetary and injunctive relief. We affirm the district court’s setting aside of the jury’s royalty award but vacate the denial of the permanent injunction and remand the case for further proceedings.