Federal Judiciary

Defendant's Motion for JMOL on Obviousness Denied

By Michael Smith

Power-One, Inc. v. Artesyn Technologies, Inc., --- F.Supp.2d ----, 2008 WL 1746634(E.D.Tex. Apr 11, 2008) (NO. CIV. A. 2:05-CV-463)
Judge: John Love
Holding: Defendant's Renewed Motion for a Judgment as a Matter of Law and Alternative Motion for New Trial of Invalidity DENIED
Plaintiff Power-One sued Defendant Artesyn Technologies for patent infringement.  In November of 2007, a jury found that Artesyn infringed seven claims of one patent, but none of the claims of the second patent.  The jury also found that Artesyn failed to prove by clear and convincing evidence that the claims of the two patents were invalid. At the close of trial, Artesyn moved for JMOL on the grounds that both patents were invalid for obviousness, and renewed that motion postjudgment, i.e. here, also seeking a new trial on the issue in the alternative.
Judge Love's opinion is an exhaustive recitation of the evidence on the obviousness issue presented at trial.  "After reviewing the record and considering Artesyn's arguments, the Court finds substantial evidence in the record supporting the jury's factual findings on validity," Judge Love concluded, "and the Court also finds that Artesyn failed to meet its burden at trial of establishing obviousness by clear and convincing evidence."
"In ruling on a motion for JMOL, the Court does not make credibility determinations and must draw all reasonable inferences in the light most favorable to the verdict," Judge Love noted, flagging the relevant standard of review of the jury's determination.  Artesyn "failed to show that the evidence points so conclusively in favor of a finding of obviousness that reasonable jurors could not arrive at a contrary verdict."

Full post as published by Eastern District of Texas Federal Court Practice on June 09, 2008 (boomark / email).