Richards Layton & Finger
 

Chief Judge Stark Denies Motion to Vacate and Rules on Disputes in a Joint Status Report

January 13, 2017

In Greatbatch Ltd. v. AVX Corp., C.A. No. 13-723-LPS, 2016 WL 7217625 (D. Del. Dec. 13, 2016), Chief Judge Stark denied plaintiff Greatbatch Ltd.’s motion to vacate the summary judgment finding of no willful infringement and ruled on numerous other disputes. Greatbatch had moved to vacate the Court’s summary judgment decision of no willfulness because the decision was issued under Seagate’s “objective prong,” which was abrogated by the Supreme Court’s Halo Electronics decision. Chief Judge Stark agreed with Greatbatch that the change in legal standard made “it necessary to reconsider the Willfulness Order,” but found that Halo did not, “in this case, require vacating the prior determination that Greatbatch is unable to prove willfulness.” Id. at *1.

Chief Judge Stark considered the motion for summary judgment de novo in light of the new standard. Under the Halo standard, the Court found that the record established pre-suit knowledge but also good faith efforts to avoid infringement. Because “Greatbatch does not point to evidence from which a reasonable jury could find any infringement of these patents by AVX was ‘egregious,’ ‘deliberate,’ atypical, or otherwise characteristic of the type of infringement that could support a finding of willful infringement . . . there is no basis on which the Court could award enhanced damages under Halo.” Id. at *3. Thus, AVX proved “that there is no genuine dispute of material fact that it did not willfully infringe” the patents-in-suit; as such, the motion to vacate was denied. Id. at *6.

The Court also addressed a number of issues from the parties’ joint status report. Chief Judge Stark denied AVX’s request to vacate the jury’s damages verdict, clarified that the issue will be bifurcated if he decided to send the issue of willfulness for the remaining patent to the jury, ordered additional briefing (simultaneous five-page briefs) on certain pretrial issues, agreed to hold a bench trial on the equitable defenses of laches and estoppel, and scheduled a hearing for a number of pending motions.

Key Points:  This appears to be one of the first District of Delaware decisions addressing the new Halo standard. In his decision, Chief Judge Stark highlighted that the Halo decision afforded the Court wide discretion on whether to award enhanced damages.