Hunting Solutions Limited Liability Company D/B/A Extreme Hunting Solutions v. William L. Knight, 16-0733

William Knight invented and patented a “Rattle Stick for Attacking Animals” intended to mimic deer sounds; he lacked resources to mass-produce it.
Knight met Randall Ferman (CEO of Hunting Solutions, L.L.C. d/b/a Extreme Hunting Solutions (EHS)) in April 2013 to develop a manufacturable prototype; EHS paid for prototype, mold, marketing, and packaging (EHS estimates ~ $35,000 plus time value).
During development, EHS substituted Knight’s patented “grunt tube” with a different vocalization (a snort wheeze) over Knight’s objection; EHS ordered a mold (about $27,000) before a written agreement was finalized.
Negotiations over exclusivity failed: Knight sought a nonexclusive license; EHS sought exclusivity (and briefly discussed buying the patent); relationship dissolved and EHS sued to recover its expenditures.
At bench trial the district court rejected EHS’s unjust enrichment claim, finding Knight had not been enriched because he had not used or profited from the product EHS developed; the court indicated EHS might have a future remedy if Knight later benefited.
On appeal, EHS argued it conferred a valuable, marketable-product benefit (transformation from concept to producible product) and should be compensated; Knight argued EHS’s product did not practice his patent (grunt reed removed) and the mold was unusable for U.S. production, so he received no benefit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Knight was unjustly enriched by EHS’s work so as to require restitution	EHS: developed a marketable, mass-producible prototype and conferred value deserving compensation	Knight: EHS’s changes (snort wheeze) and faulty mold mean EHS conferred no benefit that advances Knight’s patented product	Court held EHS failed to prove benefit was conferred; no unjust enrichment proven
Proper focus for unjust enrichment valuation	EHS: value is the services/product EHS provided, not Knight’s profits	Knight: absence of benefit (and potential harm from disclosure) defeats claim regardless of services’ cost	Court focused on whether Knight received a benefit, not on EHS’s expenditures; no benefit shown
Appropriate remedy timing for unjust enrichment here	EHS: seeks present restitution for expenditures	Knight: restitution not warranted absent current use or enrichment by Knight	Court: restitution may be available in future if Knight later uses or profits from EHS-developed product; not appropriate now
Standard of review for equitable unjust enrichment claim	N/A (procedural)	N/A	Review de novo; district fact findings given weight but not binding; affirmed district court on the merits

State ex rel. Palmer v. Unisys Corp., 637 N.W.2d 142 (Iowa 2001) (defines unjust enrichment elements and restitution framework)
Iowa Waste Sys., Inc. v. Buchanan County, 617 N.W.2d 23 (Iowa Ct. App. 2000) (equitable/unjust enrichment claims reviewed de novo)
Catipovic v. Turley, 68 F. Supp. 3d 983 (N.D. Iowa 2014) (measure of unjust enrichment damages focuses on value provided, not defendant profits)
Olson v. Nieman’s, Ltd., 579 N.W.2d 299 (Iowa 1998) (patent claim defines scope of invention; claims must particularly point out the invention)