News & Analysis as of

Apportionment Damages

Sheppard Mullin Richter & Hampton LLP

Trade Secret Trouble: Fifth Circuit Upholds Vacatur of $75 Million Damages Award

On January 21, 2026, the U.S. Court of Appeals for the Fifth Circuit issued a decision in Trinseo Europe GmbH v. Kellogg Brown & Root, L.L.C., et al that has massive implications for those prosecuting or defending trade...more

Seyfarth Shaw LLP

Left With Nothing But An Injunction: Fifth Circuit Vacates $75 Million Trade Secret Verdict After Plaintiff Fails to Apportion...

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In a case that should stand as a strong reminder to apportion your damages whenever possible, the Fifth Circuit Court of Appeals affirmed a significant post‑trial ruling in Trinseo Europe GmbH v. Harper, et al., upholding the...more

Haug Partners LLP

$10 Million Jury Award Reduced to $1 by Delaware District Court following JMOL Motion in Rex v. Intuitive: Federal Circuit Affirms

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In Rex Medical, L.P., v. Intuitive Surgical, Inc. (“Rex”), the Federal Circuit affirmed the District Court’s reduction of a jury award from $10 million to $1. At trial, with no damages experts testifying, a jury awarded $10...more

Miller Johnson

Federal Circuit Affirms $1 Nominal Damages Where Failure to Apportion Renders Damages Expert’s Testimony Unreliable 

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Rex Medical, L.P. v. Intuitive Surgical, Inc., Case No. 24-1072 (Fed. Cir. Oct. 2, 2025) - The Federal Circuit’s opinion in Rex Medical, L.P. v. Intuitive Surgical, Inc. underscores the judiciary’s strict insistence on...more

White & Case LLP

Federal Circuit Says Where Expert Evidence is Insufficient, Patent Damages Can Be Nominal

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On October 2, 2025, in Rex Medical, LP v. Intuitive Surgical, Inc., Nos. 2024-1072, 2024-1125, the U.S. Court of Appeals for the Federal Circuit affirmed a district court's preclusion of Rex's patent damages expert from...more

McDermott Will & Schulte

Damages? Apportionment among licensed properties is essential, $10 million award reduced to $1

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The US Court of Appeals for the Federal Circuit affirmed a district court decision excluding a damages expert’s testimony and reducing a jury’s $10 million damages award to nominal damages. The Court found that the plaintiff...more

Baker Botts L.L.P.

Patent Apportionment: Anything You Say in a License Agreement May Be Used Against You in a Court of Law - UPDATED May 2025

Baker Botts L.L.P. on

On May 21, 2025, the Federal Circuit “reverse[d] the district court’s denial of Google’s motion and remand[ed] for a new trial on damages.” The decision resulted in an 8-2 vote, with Judges Reyna and Stark dissenting. The...more

Baker Botts L.L.P.

Patent Apportionment: Anything You Say in a License Agreement May Be Used Against You in a Court of Law

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Over the last several years, the Federal Circuit has increasingly scrutinized patent litigants’ reliance on “comparable licenses” as a means for calculating a reasonable royalty, including whether the license needs to be...more

A&O Shearman

Federal Circuit Clarifies Requirements To Establish Convoyed Sales In Patent Damages

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On March 24, 2025, the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) issued an opinion affirming a district court’s judgement of infringement while vacating and remanding the district court’s damages...more

Axinn, Veltrop & Harkrider LLP

Apportionment of Trade Secret Damages: Will Phillips 66 Ask A Six Hundred Million Dollar Question?

In a trade secret misappropriation action, a complainant is required to prove the amount of its damages with reasonable certainty and that this amount has been caused by the misappropriation. Therefore, the trade secret...more

WilmerHale

The Broken Balance: How “Built-in Apportionment” and the Failure to Apply Daubert Have Distorted Patent Infringement Damages

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The United States patent system is designed to be a balance: in exchange for the inventor disclosing their invention to the public, pa-tentees are granted exclusive rights to that invention for a period of time. This ensures...more

Marshall Dennehey

Florida Rule of Civil Procedure 1.442(c)(3)’s Apportionment Requirement Found Inapplicable by Virtue of Rule 1,442(c)(4) as the...

Marshall Dennehey on

Webjet Linhas Aereas S.A. etc., et al. v. ZGA Aircraft Leasing, Inc., 49 Fla. Weekly D620a (Fla. 3rd DCA 2024) - On March 20, 2024, the Third District Court of Appeal rendered a decision concerning the characterization of a...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases - June 2024

EcoFactor, Inc. v. Google LLC, Appeal No. 2023-1101 (Fed. Cir. June 3, 2024) In the Federal Circuit’s only precedential patent opinion this week, the court addressed issues of infringement and admissibility that arose...more

McDermott Will & Schulte

Can’t Hide Behind Minor Clerical Error to Escape Willful Infringement Verdict

The US Court of Appeals for the Federal Circuit affirmed a district court decision correcting a clerical error in a claim. Pavo Solutions LLC v. Kingston Technology Company, Inc., Case Nos. 21-1834 (Fed. Cir. June 3, 2022)...more

McDermott Will & Schulte

One for All, and All for One . . . Except When It Comes to Patent License Comparability

Examining whether portfolio patent licenses can be sufficiently comparable to a single-patent license for the purposes of supporting a patent damages verdict, a split panel of the US Court of Appeals for the Federal Circuit...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases - September 2021 #3

Omega Patents, LLC, v. CalAmp Corp., Appeal Nos. 2020-1793, -1794, (Fed. Cir. Sept. 14, 2021) - In its only precedential patent case this week, the Federal Circuit sent a case back for a third trial on the issue of...more

Fitch, Even, Tabin & Flannery LLP

Federal Circuit Affirms Exclusion of Expert Opinion on Reasonable Royalty Rate

On August 26, in MCL Intellectual Property, LLC v. Micron Technology, Inc., the Federal Circuit affirmed exclusion of an expert opinion regarding a reasonable royalty, holding that the district court did not abuse its...more

McDermott Will & Schulte

Damage Expert Testimony Excluded for Failure to Disclose Evidence and to Apportion

The US Court of Appeals for the Federal Circuit affirmed a district court’s decision to preclude a damage expert from characterizing license agreements and opining on a reasonable royalty rate where the sponsoring party...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases - August 2021 #5

MLC Intellectual Property, LLC v. Micron Technology, Inc., Appeal No. 2020-1413 (Fed. Cir. Aug. 26, 2021) - For those interested in an important Section 112 written description case, we recommend reading the Juno...more

BCLP

The Supreme Court of Georgia Sheds New Light on Apportionment of Damages

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The Supreme Court of Georgia issued another decision in its recent line of cases opining on the scope and availability of Georgia’s apportionment statute - O.C.G.A. § 51-12-13. This latest decision, Alston & Bird, LLP v....more

McDermott Will & Schulte

Apportionment Unnecessary When Royalty Is Based on Comparable License

Rejecting a defendant’s request for a new trial on a variety of grounds, the US Court of Appeals for the Federal Circuit affirmed a damages award and explained that apportionment was unnecessary because a sufficiently...more

BCLP

Georgia's Apportionment Statute in Product Liability Lawsuits

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The Georgia Supreme Court recently issued a decision impacting all product liability cases in Georgia by finding that Georgia’s apportionment statute—O.C.G.A. § 51-12-33—applies to claims for strict product liability, and as...more

Conn Kavanaugh

Tenant May Not Recover Personal-Injury Damages Under Implied Warranty of Habitability for Slip and Fall on Icy Driveway

Conn Kavanaugh on

The Facts: Goreham v. Martins, No. SJC 12761, 2020 WL 3407710 (Mass. June 22, 2020) - On a cold day in January 2010, Robert Goreham exited his apartment through the rear fire escape and walked down the building’s driveway...more

McDonnell Boehnen Hulbert & Berghoff LLP

Hologic, Inc. v. Minerva Surgical, Inc. (Fed. Cir. 2020)

On April 22, 2020, the Federal Circuit "grappled," as the opinion put it, with the equitable doctrine of assignor estoppel in Hologic, Inc. v. Minerva Surgical, Inc., the Federal Circuit "grappled," as the opinion put it,...more

McDermott Will & Schulte

Satellite Science? No, Just a Damage Award Supported by Substantial Evidence

The US Court of Appeals for the Federal Circuit concluded that the district court did not abuse its discretion in denying defendants’ motion for a new trial on damages, finding that the jury verdict on damages was based on...more

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