MLC Intellectual Property LLC v. Micron Technology, Inc.

 
APPEAL NO.
20-1413
OP. BELOW
DCT
SUBJECT
Patent
AUTHOR
Stoll

Issue(s) Presented

1. “Did the district court err in excluding evidence of comparable-license negotiations under the parol-evidence rule in a Georgia-Pacific analysis and the resulting royalty opinions?”

2. “Did the district court err in adopting an evidentiary standard contrary to the Federal Rules to require disclosure of expert and privileged information during fact discovery?”

3. “Did the district court err in resolving factual disputes as a matter of law under Daubert rather than leaving them for the jury?”

4. “Did the district court err in requiring further apportionment of the royalty base within a single-component device based on the functionality of the component?”

Holding

1. “Because we affirm on the primary ground identified by the district court, we do not reach the parol evidence issue.”

2. “The district court acted well within its discretion when it excluded Mr. Milani’s opinion . . . and the extrinsic documents under Rule 37(c)(1) as a result of MLC’s failure to supplement its discovery responses to provide this information.”

3. “[W]e affirm the district court’s grant of Micron’s Daubert motion to exclude Mr. Milani’s expert opinion on reasonable royalty for failure to apportion. We agree that Mr. Milani did not properly apportion either the royalty base or the royalty rate to account for the patented technology.”

4. “We are also not persuaded by MLC’s argument that it need not further apportion beyond the single-component SSPPU because the asserted claims are directed to a memory device as a whole.”