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Apple Inc. v. Samsung Elecs. Co., Ltd. - 839 F.3d 1034 (Fed. Cir. 2016)

Rule:

The United States Court of Appeals for the Federal Circuit reviews a district court's order granting or denying a judgment as a matter of law (JMOL) under the standard applied by the regional circuit. In the Ninth Circuit, JMOL is proper when the evidence permits only one reasonable conclusion and the conclusion is contrary to that of the jury. The Ninth Circuit explains that the evidence must be viewed in the light most favorable to the nonmoving party, and all reasonable inferences must be drawn in favor of that party. The Ninth Circuit reviews a district court's decision to grant or deny JMOL de novo.

Facts:

Apple Inc. (Apple) filed a patent infringement suit and countersuit against Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung Telecommunications America, LLC (Samsung), alleging infringement of the ‘647 Patent and the ‘721 Patent. The ‘647 Patent disclosed a system and method for detecting structures such as phone numbers, addresses, and dates in documents, and then linking actions or commands to those structures through an “analyzer server.” On the other hand, the ‘721 Patent disclosed a portable device with a touch-sensitive display that can be “unlocked via gestures” performed on the screen. After a 13-day trial, the jury found the asserted claim of ‘647 Patent and ‘721 Patent infringed. The district court subsequently denied Samsung’s requested summary judgment as a matter of law (JMOL), and entered judgment accordingly. Samsung appealed.

Issue:

Was the denial of Samsung’s requested summary judgment as a matter of law proper?

Answer:

Yes.

Conclusion:

After noting that patent infringement was a question of fact, and appellate review was limited to whether there was substantial evidence in the record to support the jury's verdict, the Court of Appeals for the Federal Circuit held that the district court did not err by denying defendant’s JMOL because expert testimony provided substantial evidence of infringement. Substantial evidence supported the jury's finding that defendant's accused devices contained a server routine separate from a client and met the analyzer server limitation. Moreover, the Court held that Samsung failed to substantiate its claim that Apple’s ‘721 Patent was obvious under 35 U.S.C.S. § 103.

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