High Damage Awards In 2025: Judge Gilstrap's Courtroom In The Spotlight

This past year saw multiple juries award plaintiffs high-dollar damages in patent cases. As many of those verdicts came late in 2025, fewer enhancements (e.g., by tacking on interest) or reductions (e.g., by ruling in favor of a defendant on a posttrial motion) have yet materialized. Five of this year's high-dollar awards came against the same defendant, and perhaps not surprisingly six of them were returned to an Eastern District of Texas courtroom, five of those to District Judge Rodney Gilstrap alone. Moreover, a mid-year ruling in a case over which Judge Gilstrap presided, a case that produced a $300M verdict in 2021, seems to have changed one aspect of trial practice in what is the nation's busiest patent venue.

The Eastern District of Texas sits atop the list of district courts with the most patent cases. It has been there since Q2 2023, having surged back into first after temporarily losing its long-held top spot in the wake of the Supreme Court's 2017 TC Heartland decision on patent venue. Among the judges not just in that district but everywhere, Judge Gilstrap's docket is by far the busiest with patent litigation, accounting for just under 20% of all patent litigation for both the fourth quarter of 2025 and the year overall. It is not a surprise, then, that five of the highest damages awards of 2025 arose in Judge Gilstrap's courtroom.

The practice there, though, has recently shifted away from the use of a general verdict on infringement. In August 2021, an Eastern District of Texas jury returned the above-mentioned $300M verdict for several subsidiaries of PanOptis Holdings, LLC (collectively, "PanOptis") in a damages retrial against Apple. The jury awarded damages based on an earlier infringement verdict (damages from which had been overturned) in which District Judge Rodney Gilstrap asked the jury whether "ANY" of the five tried patents were infringed—despite the parties' request for a verdict form that would have addressed infringement for each patent separately.

This past June, the Federal Circuit ruled that that use of a general verdict violated Apple's Seventh Amendment right to a unanimous jury verdict, reversing and remanding for a new trial. That reversal appears in a sweeping precedential decision that also upends the denial of two invalidity challenges from Apple and holds that Judge Gilstrap abused his discretion by admitting a settlement agreement and related testimony that together, per the appeals court, prejudiced Apple. For complete coverage of that decision, see "Judge Gilstrap's Use of General Verdict Form Undercuts $300M PanOptis Award" (June 2025).

Before jumping into this past year's jury awards, note that damages characterized as lump sums are easy to quantify while those that include a running royalty are tougher. For example, a November 2023 jury verdict for VB Assets, LLC against Amazon included both an award of $46.7M (which was trimmed to around $40M through District of Delaware Judge Maryellen Noreika's rulings on posttrial motions); and an award of royalties on future sales. In late 2024, the court set ongoing royalty rates—of $0.25 "per net new Alexa shopping user" and $0.45 "per net new Alexa user". An appeal of those results is underway, but obviously the $40M figure does not capture the future-looking portion of that particular jury's award.

With all that as backdrop, below is a rundown of this past year's highest damages awards.

High Damage Awards in 2025

1. Masimo et al. v. Apple: $634.3M

In November 2025, a Central District of California jury returned a verdict for Masimo and Cercacor Laboratories, awarding the plaintiffs just over $634M against Apple (8:20-cv-00048). The jury found claims 11-14 of a single patent (10,433,776) infringed by accused versions of the Apple Watch providing a feature for alerting wearers to an abnormal heart rate under certain circumstances. As RPX reported at the time, central to the case seems to have been whether an Apple Watch is a "patient monitor", as recited in the tried claims.

This case is just one in a long-running set of disputes between Masimo and Apple, including a Masimo victory before the International Trade Commission (concerning a feature of certain Apple Watches for measuring blood oxygen levels), many Apple wins before the Patent Trial and Appeal Board (PTAB) over the more than 15 patents originally asserted here, a jury verdict for Apple in a Delaware case against Masimo, and a mistrial over some of the trade secret misappropriation claims in this same case in early 2023. For coverage of this broader backdrop, see "'Exciting Turn of Events' in Delaware Fails to Avert Jury Trial" (October 2024).

Based in Irvine, California, Masimo bills itself as "a medical technology company that revolutionized noninvasive monitoring of physiological parameters, such as pulse rate, arterial oxygen saturation and many others". Its leadership has changed over the past couple years. Its founder Joe Kiani was ousted from the board by shareholder vote in 2024, Kiani subsequently resigning as the company's CEO and Masimo then suing Kiani in Delaware's Court of Chancery over claims that he attempted to interfere with that voting process. That case remains active. Masimo's CEO since has been Katie Szyman. Kiani formed Willow Laboratories, Inc. in Nevada in January 2024, registering to conduct business in California shortly thereafter, its type of business listed as "Medical Technology". Willow Labs holds multiple US patents, many of which were assigned to it from Cercacor. Its emphasis seems to be on diabetes and blood sugar monitoring.

District Judge James V. Selna presided over the recent trial. Posttrial briefing is underway.

For further details, see "Central District of California Jury Returns Patent Verdict for Masimo" (November 2025).

2. Collision Communications v. Samsung: $445.5M

In October 2025, an Eastern District of Texas jury returned a verdict in favor of Collision Communications, Inc. (f/k/a Collision Technology, LLC) against Samsung. Six claims from four patents (6,947,505; 7,463,703; 7,593,492; 7,920,651) were found infringed and not proven invalid, with the jury awarding Collision roughly $445.5 in damages, the amount characterized as the "sum of money, if paid now in cash" that would compensate the plaintiff for the infringement proven and as a running royalty.

Collision Communications is a Concert Technology Corporation plaintiff, the ownership and control of which is not simple—as revealed through a shareholder derivative lawsuit in Delaware Chancery Court. For detailed coverage, see "Plaintiff with Complicated Connections Returns to Litigation" (December 2023). An earlier motion challenging standing in light of that backdrop never reached a ruling, as the litigation against Ericsson and Nokia concluded before the motion's resolution. A December 2023 case filed by Collision against Lenovo was dismissed with prejudice, in light of a settlement.

District Judge Rodney Gilstrap presided over the Collision trial against Samsung. Posttrial briefing is underway. Among the motions filed is Collision's motions for a permanent injunction and to shift fees. In the latter, Collision revisits a history of alleged interactions between the two companies, involving purported copying of Collision's technology that forced it to lay off staff beginning in 2019. Samsung has filed motions for judgment as a matter of law as well as a motion for a new trial, in the latter leading with two "improper jury instructions", one related to marking and pretrial damages; the other, to "the smallest salable patent practicing unit (SSPPU), improperly allowing damages on entire smartphones".

3. Headwater Research v. Samsung: $278.8M

This past April, an Eastern District of Texas jury returned a verdict that Samsung had infringed claims from two Headwater Research LLC patents (specifically, claims 1, 7, and 19 of the 8,406,733 patent and claims 1, 12, and 16 of the 9,198,117 patent) and had not shown them to be invalid. It awarded $278.8M in damages. This result came in the second of several cases that Headwater Research filed against Samsung, both in the US and abroad; the first produced a January 2025 verdict from a different East Texas jury of noninfringement (of a single Headwater patent) for Samsung. Judge Gilstrap presided over both.

In September, while posttrial motions were underway in this case, the parties filed motions to end the various suits between them, variously citing a resolution and a settlement. All have been dismissed. Left unresolved by that end is the effect of a postverdict final written decision canceling as obvious claims 1-17, 19, 21-27, and 29-30 of the '733 patent. Note that the jury here was not asked to apportion its $278.8M award between the two patents tried (or across the claims tried). The petition that led to this final written decision was filed by Alphabet (Google) and Samsung.

Headwater Research is an IP development company controlled by Greg Raleigh. A key issue in the leadup to the first two trials against Samsung was Headwater's standing to sue. Samsung unsuccessfully argued that any patented inventions properly belonged to Qualcomm as Raleigh's prior employer. The Headwater campaign (over a patent family that numbers in the hundreds) produced a second verdict on the list of high damage awards in 2025 (see below) and remains active against many other defendants.

Additional coverage is available at "Jury Returns Verdict for Headwater Research in Second Samsung Trial" (April 2025).

4. Pictiva Displays v. Samsung: $191.4M

In November 2025, an Eastern District of Texas jury returned a verdict for coplaintiffs Key Patent Innovations Limited (KPI) and Pictiva Displays International Limited against Samsung. Three claims from two former OSRAM patents were found infringed; more specifically, the jury found claims 1 and 8 of the 8,314,547 patent and claim 2 of the 11,828,425 patent infringed (and not proven invalid), while claims 34-35 of the 6,949,389 patent, claims 1-2 and 9 of the 8,558,223 patent, and claims 1, 5-6, and 9 of the 8,723,164 patent were not. The overall award came from $98.8M awarded for infringement of the '547 patent; and $92.6M, for the infringement of the '425 patent, each indirectly characterized as a lump sum.

After closing arguments, Samsung filed a motion for a mistrial based on the conduct of plaintiff's litigation counsel, whose closing argument, per that motion, "devolved into baseless, high-volume, animated attacks on the character of Samsung and its counsel—and inappropriately invoked Christian Scripture, to boot". For detailed coverage of that motion, see "East Texas Jury Returns Verdict for Pictiva After Samsung Seeks Mistrial" (November 2025). Samsung includes the same arguments in a motion for a new trial, which leads with other issues, some of them overlapping with those raised in its concurrent, renewed motions for judgments as a matter of law. Pictiva seeks fees (citing conduct that did not convince Judge Gilstrap to enhance damages for willfulness) and also asks for a new trial over the three patents not found infringed.

Pictiva pleads that it was formed in Ireland (as were KPI and its other portfolio-holding entities) and that it operated as "Dolya Holdco 5 Limited until July 17, 2020". KPI characterizes itself on its public website as "an Irish-based company that identifies and invests in high value patent-based opportunities", listing a team of directors headed by Angela Quinlan. Years ago, IAM reported that in 2020, with backing from private equity firm Centerbridge Partners, KPI acquired over "1,400 worldwide patent assets from lighting business Osram", assets that are now held by Pictiva. It has active litigation through three plaintiffs: Pictiva (over those former OSRAM patents) as well as Malikie Innovations Limited (over a former BlackBerry portfolio) and Valtrus Innovations Limited (over former HP Enterprise (HPE) patents).

5. Headwater Research v. Cellco Partnership (d/b/a Verizon Wireless): $175M

In July 2025, an Eastern District of Texas jury returned a verdict for Headwater, finding claim 1 of the 9,215,613 patent and claim 83 of the 8,589,541 patent infringed by Verizon (Verizon Wireless). The jury awarded $175M as a lump sum. No willfulness was found. Judge Gilstrap presides over this matter as well, the court setting a bench trial over certain equitable defenses for February 4, 2026. That date has been moved in light of several sealed filings that seem to suggest that some, but not all, of the claims against this defendant have been resolved.

The bench trial has also pushed off posttrial briefing. Verizon Wireless has notified the court of a final written decision from the PTAB ruling claims 2-23, 26, 41-60, 63, 64, 91-152 and 155-171 of the '541 patent unpatentable. While claim 83 was not canceled, Verizon notes that "each element of the sole independent claim 1, upon which the only asserted claim of the '541 Patent in this matter depends, has been anticipated by prior art". It represents that this development is relevant "as supplemental authority in connection with its damages positions in Rule 50(b) and Rule 59 motions, if necessary following the Court's adjudication of Verizon's equitable defenses".

Additional background concerning Headwater's litigation against Verizon Wireless and the other two major US wireless carriers can be found at "More Jury Trials Looming, Headwater Research Secures Verdict Against Verizon Wireless, Receives PTAB Blow to Prior Samsung Verdict" (November 2025).

6. Express Mobile v. GoDaddy: $170M

In November 2025, a Delaware jury returned a verdict in favor of Express Mobile, Inc. (XMO), awarding the plaintiff $170M from defendant GoDaddy for the infringement of two patent claims, one from each of two "Web Design" patents (claim 2 of the 6,546,397 patent and claim 1 of the 7,594,168 patent). The jury characterized the infringement found as willful and found neither claim proven invalid at trial before Northern District of Illinois Judge Matthew Kennelly, sitting by designation. Posttrial briefing has begun, with the parties arguing over, among many other things, how many motions, briefs, and pages can be devoted to the process.

This campaign has been active for over a decade now, and the verdict against GoDaddy was not XMO's only win before a jury. In 2022, a different Delaware jury awarded it $40M against Shopify for infringement of three "Web Component" patents, but District Judge Richard G. Andrews overturned that result on posttrial motions. Judge Andrews had granted Shopify summary judgment of noninfringement of two other XMO patents and then granted Shopify's renewed motion for judgment as a matter of law of no infringement of the three tried to the jury. In early December 2025, the Federal Circuit dismissed an XMO appeal of that ruling as moot as to multiple claims canceled as unpatentable in parallel PTAB proceedings and affirmed Judge Andrews as to the rest. Away goes that $40M verdict.

Based in Marin County, California, XMO was formed in Delaware in September 2006. Its life cycle appears to have passed through several stages, including business and technology development (through around 2015); early monetization efforts (from 2015 through the fall of 2020); and current monetization efforts (after an August 2020 shift in leadership). For more detailed coverage of XMO and this long-running litigation (which remains active against multiple other defendants), see "Tailwinds in District Court, Headwinds at the Federal Circuit, for XMO" (November 2025).

7. Maxell v. Samsung: $111.7M

In May 2025, an Eastern District of Texas jury returned a verdict finding that Samsung had infringed tried claims from three Maxell patents (8,982,086; 10,176,848; 11,017,815); that the infringement had been willful; and that Samsung had not shown either the '086 or '815 patents to be invalid. The jury awarded a total of roughly $112M in damages—including around $38.1M for the '086 patent, $28.2M for the '848 patent, and $45.4M for the '815 patent—indicating that this amount was based on a 1% "running royalty for each patent through trial".

That win did not last long, however, as District Judge Robert W. Schroeder, III granted JMOL for the defendant on various grounds this past September, toppling the $112M award. Prior to trial, the court had granted summary judgment of noninfringement to Samsung on two other patents asserted in this case (10,129,590; 11,223,757). Maxell filed an appeal but has since asked the Federal Circuit to stay that appeal pending resolution of related proceedings at the PTAB.

Maxell has other cases pending against Samsung, in the US and abroad. It has also sued various other companies in this same campaign both in district court and before the International Trade Commission (ITC). For additional background, see "Maxell's $112M Verdict Against Samsung Falls in Posttrial Challenge" (September 2025).

8. TOT Power Control v. Apple: $110.7M

In June 2025, a Delaware jury returned a verdict in TOT Power Control, S.L.'s favor, awarding a running royalty of just over $110M (calculated at $0.25 per unit) against Apple for the infringement of claims 5-6 from a single cellular communications patent (7,532,865). The jury found those claims not proven invalid for obviousness and claim 6 of the 7,496,376 patent not proven infringed. The court's Judgment Following Jury Verdict clarifies that claims 5-6 of the '865 patent were found literally infringed and that the failed '376 patent infringement case was based on the doctrine of equivalents.

This trial is the first in TOT Power's campaign, which has also hit wireless carriers AT&T (AT&T Mobility), Deutsche Telekom (Sprint, T-Mobile), and Verizon (Verizon Wireless) and other device makers LG Electronics (LGE) and Samsung since its 2021 inception. TOT Power is a Spanish entity describing itself in its complaints as "an intellectual property and technology licensing company" holding a patent portfolio "based on technology conceived, developed and patented by its President, Alvaro Lopez-Medrano, along with four colleagues". On its public website, TOT Power's parent TOP Optimized Technologies SL (d/b/a InToTally) indicates that Alvaro "holds four international fundamental wireless patents regarding a breakthrough solution for power control in 3G mobile technology", from which the two asserted patents are drawn. Their general subject matter is the use of outer loop power control (OLPC) in cellular network communications.

Posttrial briefing is underway before District Judge Maryellen Noreika. The suits against Sprint and Verizon ended in quick dismissals without prejudice. Judge Noreika has temporarily stayed the cases against LGE and Samsung, to await her rulings on posttrial motions in the case against Apple. Judge Albright presides over the suits against AT&T and T-Mobile in West Texas; trial has been reset, from July 2026 to April 2027.

For more on this verdict, see "Delaware Jury Awards $110M in First Trial in TOT Power Control Campaign" (July 2025).

9. VidStream v. X (f/k/a Twitter): $105.4M

This past April, a Northern District of Texas jury returned a verdict in favor of VidStream LLC, awarding it over $105M against X (f/k/a Twitter). Six claims from two patents were tried, the patents generally related to "a system of receiving and distributing user-generated video content for distribution on television broadcasts and the Internet". The jury found claim 17 of the 8,464,304 patent infringed and not proven invalid. Claims 22-24 of the '304 patent and claims 23-24 of the 8,601,506 patent were found not infringed and proven invalid.

The verdict dropped in a case first filed in March 2016, by a different plaintiff, Youtoo Technologies, LLC, over patents that were invalidated under Alice years ago, only to have VidStream step in with new counsel and successfully seek a reboot of the case, which request District Judge David C. Godbey granted in April 2021. The oddness of this campaign just begins there, though. For background coverage, see "VidStream Prevails in Northern District of Texas Trial Against X" (April 2025) and then "Preliminary Injunction Denied in Long-Running, Resuscitated Media Delivery Case" (July 2024). (Detailed at that first linked article is VidStream's apparent backing by Covenant Global Alpha Fund, L.P.)

The case against X has reached a judgment. Judge Godbey denied X's posttrial attacks on the verdict, the court awarding X the $105.4M along with $67M in prejudgment interest (from March 2015 through May 2025). The postjudgment interest rate was set at an 3.66% annual rate. X has appealed.

10. Anonymous Media Research Holdings v. Samsung: $78.5M

In September 2025, an Eastern District of Texas jury found claims 1, 5, 9, and 13 of the 10,719,848 patent and claim 1 of the 10,963,911 patent infringed by Samsung and not proven invalid. In its verdict, it found $78.5M to be the "sum of money, if paid now in cash" that "would compensate Anonymous Media for Samsung's infringement", with 52 percent of the sum attributed to infringement of the '848 patent; 48 percent, to that of the '911 patent. Public records indicate that Anonymous Media has received funding from a hedge fund.

However, the other case in this campaign, also filed in September 2023 but against Roku, was transferred from the Western District of Texas to the Northern District of California, where District Judge Vince Chhabria (11 days after a conflicting summary judgment ruling in Texas) invalidated seven Anonymous Research patents, including the '848 patent, in light of Alice. Samsung has asked Judge Gilstrap to certify for interlocutory appeal his denial of its motion for invalidity under Alice, to allow the Federal Circuit "to provide timely guidance on a purely legal issue that has divided district courts addressing the same patent family".

Anonymous Research opposed the request for certification, arguing that the circumstances here do not meet the applicable standard (e.g., by arguing that a patent eligibility determination is a mixed question of both fact and law, not a "purely legal issue"). Judge Gilstrap has yet to rule.

For more on those differing outcomes, see "California and Texas Courts Produce Near-Simultaneous Conflicting Results in Targeted Advertising Campaign" (September 2025).

A Post Script to the High Damage Awards from 2024

At the end of 2024, RPX compiled a list of high-dollar jury awards from that year as well, noting where the district court had augmented or reduced the jury's amount:

Top Damage Awards in 2024

Over the intervening 12 months, the parties in three of those cases ended the dispute, with a settlement (General Access Solutions, Ltd.), a resolution (IPA Technologies Inc., a subsidiary of Wi-LAN Inc.), or a dismissal with prejudice (MR Technologies, GmbH). An appeal to the Federal Circuit in the Kove IO, Inc. matter is awaiting oral argument, while respective appeals from the judgments for Netlist against Micron Technology and for AlmondNet, Inc. against Amazon are just getting started (rulings on posttrial motions in those cases having pushed well into 2025). Judge Gilstrap has yet to rule on the posttrial motions in the Netlist suit against Samsung noted above, the Mojo Mobility against Samsung in a similar state. The court has rejected an attorney fees shift request from Centripetal and has since put prejudgment interest at $33.7M.

Most notably, though, was Central District of California Judge James V. Selna's amended judgment in the SPEX Technologies, Inc. case against Western Digital, handed down in June 2025. There, the court agreed with defendant Western Digital that problems with the plaintiff's damages cases rendered the jury's award of more than $300M unsupported by sufficient evidence. Judge Selna left the infringement finding intact but wiped out the figure that the jury returned in favor of nominal damages. Underscoring how a jury's say is almost never the final say, the court set that nominal award at $1. An appeal is underway.

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