Uniloc USA, Inc. v. Microsoft Corp., 10-1035
Patent infringement action against Microsoft Uniloc USA, Inc. v. Microsoft Corp., 10-1035, concerned various challenges to the district court's judgment in plaintiff's suit for infringement of the '216 patent against Microsoft, directed to a software registration system to deter copying of software.
The court reversed the district court's grant of JMOL of
non-infringement as the jury's verdict on infringement was supported by
substantial evidence. The court also reversed the district court's
alternative grant of a new trial on infringement as an abuse of
discretion. However, the court affirmed the district court's grant of
JMOL of no willfulness because the jury's verdict on willfulness was not
supported by substantial evidence, and as such, the district court's
alternative grant of a new trial for willfulness is rendered moot. The
court granted a new trial on damages in concluding that the jury's
damages award was fundamentally tainted by the use of a legally
inadequate methodology. Lastly, the court affirming the district
court's denial of Microsoft's motion for JMOL of invalidity as the
district court did not abuse its discretion in determining that the jury
verdict of no invalidity of the '216 patent was supported by
substantial evidence.
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