Meyer Intellectual Properties Ltd. v. Bodum, Inc.
764 F. Supp. 2d 1004
N.D. Ill.2011Background
- Meyer prevailed at a November 2010 jury trial on patent infringement by Bodum relating to Meyer's Patents '087 and '122.
- Jury found the Meyer Patents valid and Bodum's infringement willful, and awarded Meyer $50,000 in damages.
- Meyer seeks treble damages under 35 U.S.C. § 284 and an exceptional-case attorney-fee award under § 285, plus related fees.
- Court applies the Read Corp. factors (and related Fed. Cir. precedent) to decide both damages enhancement and fees.
- Court finds Bodum acted in bad faith, supporting enhanced damages and an award of attorney’s fees, after considering each Read factor.
- Final rulings: damages increased to $150,000 (3x the verdict) and Meyer awarded $756,487.56 in fees, for total judgment of $906,487.56.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether willful infringement supports enhanced damages | Meyer: Bodum's copying and bad faith justify enhancement. | Bodum: no willfulness or improper conduct proven. | Yes; willful infringement supports enhanced damages. |
| Whether Read factors support enhanced damages in this case | Read factors favor Meyer's claims of bad faith and copying. | Read factors do not justify such enhancement. | Yes; Read factors collectively favor Meyer, supporting extra damages. |
| Whether attorney's fees should be awarded under § 285 and amount | Fees warranted as exceptional case; lodestar justified by market rates and hours. | Fees should be constrained by relation to compensatory award and excessive time concerns. | Yes; fees awarded; amount set at $756,487.56. |
Key Cases Cited
- Mentor H/S, Inc. v. Medical Device Alliance, Inc., 244 F.3d 1365 (Fed. Cir. 2001) (two-step framework for §284 enhanced damages)
- Read Corp. v. Portec, Inc., 970 F.2d 816 (Fed. Cir. 1992) (factors guiding enhanced damages and counsel-fee decisions)
- nCube v. SeaChange Int'l, Inc., 436 F.3d 1317 (Fed. Cir. 2006) (analogous factors for §284/§285 considerations)
- i4i Ltd. P'ship v. Microsoft Corp., 598 F.3d 831 (Fed. Cir. 2010) (clarified Read factor framework for good faith and reliance)
- In re Seagate Tech., LLC, 497 F.3d 1360 (Fed. Cir. 2007) (adopted view on willfulness separate from Read framework)