Garmin Switzerland GMBH v. Navico, Inc., 2:16-cv-02706

Plaintiffs Garmin sued C‑MAP alleging infringement of U.S. Patent No. 7,268,703 and filed an amended complaint; deadline to move for further amendment was May 19, 2017.
Plaintiffs served interrogatories; C‑MAP responded it first learned of the ’703 patent in 2011–2012.
Based on that response, plaintiffs sought leave to amend to add willful‑infringement allegations, filing the motion within the scheduling deadline.
C‑MAP opposed, arguing the proposed willfulness allegations are futile because mere knowledge plus continued infringement does not plead the egregiousness required for enhanced damages under 35 U.S.C. § 284 post‑Halo.
Plaintiffs pointed to factual allegations (e.g., a prior self‑imposed restriction on enabling the accused technology in U.S. waters that ceased in August 2016) and the interrogatory response as supporting a plausible claim of willfulness.
The court granted leave to amend, finding the amended allegations, taken together, state a plausible willful‑infringement claim and permit discovery on the issue; related pending motions were dismissed as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether leave to amend to add willful‑infringement allegations should be granted	New discovery (interrogatory response that C‑MAP knew of the patent in 2011–2012 plus other factual allegations) makes willfulness plausible and merits discovery	Amendment is futile because allegations amount only to knowledge + continued infringement, which is insufficient to show the egregious conduct required for enhanced damages	Granted: Court found plaintiffs’ combined factual allegations plausible enough to state a willfulness claim and permitted amendment and discovery

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (apply plausibility standard and accept well‑pled facts)
Ridge at Red Hawk, L.L.C. v. Schneider, 493 F.3d 1174 (complaint must give reason to believe plaintiff can produce factual support)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (pleading standard does not require showing ultimate success; entitlement to offer evidence)
Halo Electronics, Inc. v. Pulse Electronics, Inc., 136 S. Ct. 1923 (enhanced damages reserved for egregious, willful misconduct)