Judge: Michael Schneider
Holding: Motion for Application of Collateral Estoppel Granted
Sometimes a verdict doesn't even get to the appellate stage before it is reversed.
In 2009, the plaintiff in this case filed a patent infringement action against multiple defendants in the Eastern District of Texas. The cases were subsequently transferred to the Northern District of California. While that litigation proceeded, the plaintiff filed a subsequent case against defendant Texas Instruments.
Last spring, the Court conducted two jury trials in this case. The first found that the asserted claims (the "Early Transmit Patents") were not shown to be invalid by clear and convincing evidence, and the second found that the asserted claims were infringed and assessed damages of $3 million. While the Court entered a final judgment after rejecting the defendant's equitable defense of laches, the court specifically noted that it was still considering the issues raised in the parties' postverdict briefing, including the validity of the Early Transmit Patents.
While the post verdict briefing was pending, the Northern District of California invalidated the early transmit patents. After TI notified the Court of this action, Judge Schneider ordered the parties to brief the applicability of collateral estoppel in this case, and concluded that it did apply. Accordingly, the court held that the plaintiff was precluded from recovering on the damages awarded for infringement in this case because the patent have now been declared invalid.