Jiaxing Super Lighting Electric Appliance, Co. v. CH Lighting Technology Co.

 
APPEAL NO.
23-1715
OP. BELOW
DCT
SUBJECT
Patent
AUTHOR
Dyk

Issue(s) Presented

1. “Whether the district court erred in excluding evidence on invalidity and granting partial JMOL for plaintiffs on that issue.”

2. “Whether defendants are entitled to JMOL that claim 1 of the ’140 patent is invalid, or that products with LT2600 chips do not infringe that patent.”

3. “Whether plaintiffs’ damages evidence was inadmissible and insufficient to support damages.”

Holding

1. “[T]he district court erred in granting JMOL that the ’125 and ’540 patents were not invalid because it erroneously prevented CH Lighting from presenting evidence of their invalidity; the district court was required to hold a new trial as to the invalidity of the ’125 and ’540 patents.”

2. “[W]ith respect to the ’140 patent, substantial evidence supports the jury’s verdicts of infringement and no invalidity.”

3. “[T]he district court should assess the reliability of Ms. Kindler’s testimony consistent with this court’s recent en banc decision in EcoFactor and under Rule 702 of the Federal Rules of Evidence. Accordingly, a new trial is required as to the validity of the ’125 and ’540 patents and as to damages for infringement of all three patents.”