Lear Corporation v. NHK Seating of America Inc, 2:13-cv-12937

Lear Corporation owns five patents directed to headrests that move on front or rear impact and alleges NHK Seating of America (NHK) makes or sells products that infringe various claims across those patents.
NHK moved for summary judgment in September 2018, arguing it did not infringe the asserted claims.
Lear moved to strike new non-infringement theories asserted in NHK’s summary-judgment motion, contending those theories were not in NHK’s Final Non-Infringement Contentions.
The Court reappointed Retired Judge James F. Davis as special master to expedite resolution, limiting each party to objecting on two (or, if necessary, three) summary-judgment issues for Court review while allowing preservation of issues for appeal.
Special Master Davis issued two Reports & Recommendations: (1) deny NHK’s summary-judgment motion in full, and (2) deny Lear’s motion to strike but permit certain supplementation of Lear’s final infringement contentions.
Lear filed no objections; NHK filed broad objections purporting to preserve all non-infringement positions for appeal. The Court viewed NHK’s objections as preservation for appeal and adopted both special-master reports and recommendations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NHK’s accused products infringe the asserted claims (summary judgment for NHK)	Lear argued NHK’s products meet disputed claim limitations and summary judgment is premature given disputed facts and claim construction issues	NHK argued it does not infringe and advanced non-infringement theories beyond its final contentions	Court adopted Special Master: deny NHK’s summary-judgment motion (factual/disputed issues remain)
Whether NHK may present allegedly new non-infringement theories and whether those should be struck	Lear argued NHK raised new theories not in its Final Non-Infringement Contentions and asked to strike them	NHK defended its theories (and broadly preserved objections for appeal)	Court adopted Special Master: deny Lear’s motion to strike but permit Lear to supplement infringement contentions in limited respects
Whether the Court will adopt Special Master Davis’s recommendations	Lear did not object; Lear sought relief through the special master process	NHK lodged broad objections to preserve appellate rights but did not narrow issues for this Court’s review	Court adopted Special Master Davis’s reports and accepted his recommendations; viewed NHK’s objections as appellate preservation

No official reported cases are cited in the court’s order.