American Axle & Manufacturing, Inc. v. Neapco Holdings LLC
1:15-cv-01168
D. Del.Sep 17, 2025Background
- Plaintiff American Axle & Manufacturing, Inc. sued Neapco Holdings LLC and Neapco Drivelines LLC; a jury awarded damages and judgment was entered.
- Plaintiff moved for supplemental damages ($1,060), pre-judgment interest, and post-judgment interest.
- Defendants moved for approval of a supersedeas bond to stay execution of judgment; they obtained a bond of $4,297,076.42 which did not include pre-judgment interest.
- Parties agreed supplemental damages amount and statutory post-judgment interest rate; they agreed on using prime rate compounded quarterly for pre-judgment interest calculation.
- Defendants opposed pre-judgment interest arguing (1) plaintiff caused undue delay, (2) requested interest would be punitive, and alternatively asked interest be limited to period before plaintiff sought a stay.
- Court resolved motions by written Memorandum Order: granted supplemental damages, pre-judgment interest, and post-judgment interest; denied defendants’ bond motion without prejudice because the bond omitted pre-judgment interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Award of supplemental damages | Parties agree $1,060 for sales not in verdict | No opposition | Granted $1,060 |
| Pre-judgment interest: entitlement and period | Award interest from first infringement through judgment at prime rate compounded quarterly; include on verdict + supplemental damages | Deny because plaintiff caused delay; amount punitive; if awarded, limit to pre-stay period | Granted $1,196,900; court found stay pending cert. petition did not constitute undue delay and amount is compensatory under agreed methodology |
| Post-judgment interest rate and compounding | Award statutory rate (4.76% for the relevant week) compounded annually on verdict + supplemental + pre-judgment interest | No opposition | Granted at agreed statutory rate compounded annually |
| Sufficiency of defendants’ supersedeas bond | N/A; defendants presented bond covering verdict, supplemental damages, and ~18 months post-judgment interest but not pre-judgment interest | Bond insufficient because it omits the awarded pre-judgment interest; request to approve stay should be denied or amended | Denied without prejudice; defendants may refile under Rule 62(b) with a bond covering the full judgment plus interest |
Key Cases Cited
- Roche Diagnostics Corp. v. Meso Scale Diagnostics, ELC, 503 F. Supp. 3d 156 (D. Del.) (prejudgment interest normally awarded in patent cases to provide full compensation; courts may deny where party caused undue delay)
- Crystal Semiconductor v. TriTech Microelectronics Int’l, 246 F.3d 1336 (Fed. Cir.) (affirmed denial of prejudgment interest where plaintiff’s litigation tactics caused multi-year undue delay)
- VICI Racing, LLC v. T-Mobile USA, Inc., 921 F. Supp. 2d 317 (D. Del.) (supersedeas bond should generally be sufficient to satisfy judgment plus interest and costs)