Krippelz v. Ford Motor Co., 667 F.3d 1261

Ford appeals a $56 million judgment in a patent infringement case involving the Krippelz ’903 patent for an automotive emergency light.
Krippelz sued Ford in 1998 over Ford’s puddle light, leading to jury verdicts on infringement and later willfulness and enhanced damages.
The PTO reexamined the ’903 patent and ultimately reaffirmed the patentability of its claims, adding new claims not at issue here.
The district court held infringement and willfulness against Ford and Krippelz obtained substantial damages, which Ford challenged with JMOL motions.
The Seventh Circuit reversed on the validity issue, holding claim 2 invalid over DuBois for anticipation and remanded for judgment of non-liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is claim 2 invalid for anticipation by DuBois?	Krippelz argued DuBois lacks a conical beam and is not adjacent to the window.	Ford contends DuBois discloses a lamp and beam meeting all claim 2 limitations.	Yes; claim 2 invalid for anticipation by DuBois.
Do remaining issues survive given invalidity of claim 2?	Ford’s infringement and willfulness rulings should stand if valid.	Invalidity defeats liability; mootness applies to other rulings.	Moot; other rulings vacated and remanded for non-liability.

Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim construction relies on intrinsic evidence and prosecution history)
Sitrick v. Dreamworks, LLC, 516 F.3d 993 (Fed. Cir. 2008) (conclusory expert testimony cannot create a triable issue)
Seachange Int’l, Inc. v. C-COR Inc., 413 F.3d 1361 (Fed. Cir. 2005) (standard for reviewing denial of JMOL in patent cases)
Campbell v. Miller, 499 F.3d 711 (7th Cir. 2007) (standard for appellate review of JMOL in district courts)
Nystrom v. TREX Co., 424 F.3d 1136 (Fed. Cir. 2005) (avoid reliance on drawings not tied to specification values)