Halo Does Not Prohibit Jury Finding of Willfulness

The court denied defendant's motion for judgment as a matter of law that it did not willfully infringe plaintiff's capacitor patent and rejected defendant's argument that the jury finding of willful infringement was void under a recent Federal Circuit decision. "In [Halo Elecs., Inc. v. Pulse Elecs., Inc., No. 14-1513, 579 U.S. __ (June 13, 2016)], the Supreme Court rejected the Federal Circuit’s two-part test from Seagate for determining when a district court may award enhanced damages as inconsistent with § 284. The Supreme Court explained that § 284 commits the award of enhanced damages to the discretion of the district court. . . . In the present case . . . [t]he jury . . . found by clear and convincing evidence that [defendant's] infringement of the [patent-in-suit] was willful. . . . [Defendant] is correct that in Halo, the Supreme Court held that the ultimate decision of whether to award enhanced damages and in what amount is committed to the sound discretion of the trial court. But there is no language in Halo holding that a finding as to whether the infringement was willful must be made by the Court. . . . [T]he Court properly permitted the jury to issue a finding as to whether [defendant's] infringement was willful and the jury’s finding as to this issue is not void."

Presidio Components, Inc. v. American Technical Ceramics Corp., 3-14-cv-02061 (CASD June 17, 2016, Order) (Huff, J.)