In a patent dispute between Optis Cellular Technology and Apple Inc., the Federal Circuit vacated a $300 million jury verdict in favor of Optis and ordered a new trial. The case arose from Optis' claim that Apple's products implementing the LTE standard infringed five of its standard-essential patents (SEPs). The jury found Apple liable and awarded $506.2 million in damages, which was later reduced to $300 million in a second trial after the district court ordered a new trial on damages due to FRAND licensing concerns.
Apple appealed, arguing that the jury verdict form improperly combined infringement of the five asserted patents into a single generalized question of infringement. The Federal Circuit agreed, ruling that the district court violated Apple's Seventh Amendment right to a jury trial by using a general verdict form that asked if Apple had infringed any of the asserted claims, rather than requiring a separate finding for each individual patent. This error allowed jurors to issue a verdict for Optis without reaching unanimous agreement on any specific patent, which undermined the integrity of the verdict.
The court emphasized that when multiple patents are asserted, each asserted patent constitutes a separate legal claim requiring the jury to make an infringement determination for each one. Additionally, because the damages award was a lump sum based on aggregated infringement, the court ordered that damages must also be reassessed on a patent-by-patent basis.
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