News & Analysis as of

Apportionment Patent Infringement

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 

Miller Johnson on

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

White & Case LLP on

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

McDermott Will & Schulte on

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

A&O Shearman

Federal Circuit Clarifies Requirements To Establish Convoyed Sales In Patent Damages

A&O Shearman on

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

WilmerHale

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

WilmerHale on

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

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

Fitch, Even, Tabin & Flannery LLP

Where Is the Federal Circuit on Using Comparable Licenses to Prove Reasonable Royalties and Apportionment in Patent Cases?

In patent litigation, the adequacy of proof of apportionment in reasonable royalty damage claims is often a challenging issue that is hotly contested by the parties. The Federal Circuit has recently focused on the use of...more

Knobbe Martens

Intrinsic Record Thwarts Theory of Interchangeability

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APPLE INC. V. WI-LAN INC. Before Moore, Chief Judge, Bryson, and Prost.  Appeal from the United States District Court for the Southern District of California. Summary: Construing a broad claim term to be re-defined as...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

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

BakerHostetler

Baked-In Apportionment

BakerHostetler on

In Vectura, the Federal Circuit recently reiterated that the entire market value of an accused multicomponent product may serve as the royalty base if the patent damages analysis is built on sufficiently comparable licenses....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

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

Knobbe Martens

Panel on IP Valuation: How Much is it Worth? How Much Can You Get? How Can You Protect It?

Knobbe Martens on

Assessing Damages in Patent Litigation - Patent Damages - • Damages for infringement shall be “adequate to compensate for the infringement, but in no event less than a reasonable royalty for the use made of the...more

Knobbe Martens

Federal Circuit Review - February 2018

Knobbe Martens on

Improperly Drafted Employment Agreement Leads to Dismissal of Patent Case Due to Lack of Standing - In Advanced Video Technologies LLC v. HTC Corporation et al., Appeal Nos. 2016-2309, 2016-2310, 2016-2311, the Federal...more

McDermott Will & Schulte

Re-Examination Findings Not Dispositive in District Court Proceeding

Finding that rulings on validity from re-examination proceedings are not dispositive of validity in a district court proceeding, the US Court of Appeals for the Federal Circuit vacated summary judgment of no invalidity as...more

McDermott Will & Schulte

Apportionment Must Reflect No More than Invention’s Incremental Value

The US Court of Appeals for the Federal Circuit reinforced its guidance on infringement damages, remanding in part a jury’s award for further consideration of the proper apportionment. Finjan, Inc. v. Blue Coat Systems, Inc.,...more

Mintz - Intellectual Property Viewpoints

Federal Circuit Approves Apportioning Damages through a Thorough and Reliable Analysis of the Royalty Rate

On January 12, 2018 in Exmark Manufacturing Co. Inc., v. Briggs & Stratton Power Products Group, LLC, the Federal Circuit once again addressed the issue of apportioning damages, an area of the law that continues to evolve....more

Mintz - Intellectual Property Viewpoints

Damages Apportionment For Infringing A Method Claim When The Smallest Saleable Unit Performs Infringing and Non-Infringing...

The Federal Circuit’s damages apportionment jurisprudence is an ever-evolving area of the law. On January 10, 2018, a three judge panel of the Federal Circuit revisited the issue in connection with a patent covering a method...more

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