Hydrodynamic Industrial Co Ltd v. Green Max Distributors Inc
2:12-cv-05058
C.D. Cal.Jun 10, 2014Background
- Hydrodynamic Industrial Co. Ltd. holds a patent and obtained a jury verdict finding Green Max Distributors, Inc. infringed it.
- Hydrodynamic seeks a permanent injunction to stop Green Max from selling the infringing X-treme sea scooter and related user manual.
- Court analyzes the four-factor test for permanent injunction under 35 U.S.C. § 283 as refined by Apple Inc. v. Motorola and eBay v. MercExchange.
- Evidence links the patented features to consumer demand and shows Green Max copied those features in the X-treme scooter.
- Hydrodynamic presents extensive evidence of irreparable harm including market competition, price erosion, loss of goodwill, and lost business opportunities.
- Court grants a permanent injunction as the equitable factors weigh in Hydrodynamic’s favor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Irreparable harm and causal nexus | Hydrodynamic: infringement causes irreparable harm via causal nexus to demand. | Green Max: nexus between infringement and harm is insufficient. | Nexus and irreparable harm shown; injunction granted |
| Adequacy of money damages | Damages are insufficient to fully compensate Hydrodynamic given ongoing infringement and market impact. | Damages award indicates adequacy of money relief. | Damages insufficient; equity relief warranted |
| Balance of hardships | Injunction imposes hardship on Green Max, but Hydrodynamic bears greater ongoing harms. | Injunction would unduly burden Green Max for a single product. | Hydrodynamic’s hardship outweighs Green Max’s; injunction appropriate |
| Public interest | Protecting patent rights serves innovation and public safety by preventing inferior products. | Injunction could limit consumer choices and have public consequences. | Public interest favors injunction; narrow scope preserves public welfare |
Key Cases Cited
- Apple Inc. v. Samsung Elecs. Co., Ltd., 678 F.3d 1314 (Fed. Cir. 2012) (causal nexus and irreparable harm in injunctive relief substantial but not automatic)
- Apple Inc. v. Samsung Elecs. Co., Ltd., 735 F.3d 1352 (Fed. Cir. 2013) (irreparable harm and injunction standards for patent cases)
- eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (S. Ct. 2006) (four-factor test for permanent injunction)
- Innogenetics, N.V. v. Abbott Labs., 512 F.3d 1363 (Fed. Cir. 2008) (patentee not automatically entitled to injunction after liability)
- Bosch LLC v. Pylon Mfg. Corp., 659 F.3d 1142 (Fed. Cir. 2011) (irreparable harm and market impact considerations in injunctive relief)
- Reebok Int’l, Ltd. v. J. Baker, Inc., 32 F.3d 1552 (Fed. Cir. 1994) (future infringement and irreparable harm considerations)
- i4i Ltd. P'ship v. Microsoft Corp., 598 F.3d 831 (Fed. Cir. 2010) (public-interest considerations in injunctions)