Qorvo, Inc. v. Akoustis Technologies, Inc.
1:21-cv-01417
| D. Del. | Oct 31, 2024Background
- On May 17, 2024, a jury in Delaware found Akoustis Technologies, Inc. liable for trade secret misappropriation (DTSA & NCTSPA) and willful patent infringement of two Qorvo patents.
- The jury awarded Qorvo $31,315,214 in unjust enrichment and $7,000,000 in punitive damages.
- Defendants filed post-trial motions for judgment as a matter of law, a new trial, and remittitur, disputing liability, damages methodology, and admissibility of expert testimony.
- Defendants challenged the consistency of the verdict form, sufficiency of evidence for patent infringement, and reliability/qualifications of Qorvo’s damages expert and technical expert.
- The court held hearings and reviewed the parties’ arguments, expert reports, and trial testimony.
- Judge McCalla denied all defense motions, letting the jury's verdict and damages stand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Verdict form inconsistency | Any inconsistency can be harmonized or is harmless; no effect on damages. | Inconsistent verdict indicates juror confusion, affecting rights. | No irreconcilable inconsistency; not grounds for new trial. |
| Evidence sufficiency (patent claims) | Substantial evidence supports the verdict; simulation and expert testimony were proper. | Verdict unsupported; simulation data unreliable and plots inconclusive. | Sufficient evidence; issues go to weight, not legal sufficiency. |
| Admissibility of damages/technical expert testimony | Testimony was based on reliable methodology and proper qualifications. | Head start damages unreliable; experts unqualified/lacked precedent for method. | Testimony admissible; credibility/weight for jury, not the court. |
| Remittitur | N/A | Seeks reduction based on same flawed grounds as other motions. | Denied; no independent basis, arguments already rejected. |
Key Cases Cited
- Eshelman v. Agere Sys., Inc., 554 F.3d 426 (3d Cir. 2009) (standard for judgment as a matter of law; evidence must be viewed in light most favorable to nonmovant)
- Marra v. Philadelphia Hous. Auth., 497 F.3d 286 (3d Cir. 2007) (court should not weigh evidence or determine witness credibility on such motions)
- Boyanowski v. Cap. Area Intermediate Unit, 215 F.3d 396 (3d Cir. 2000) (inconsistent jury verdicts alone not enough to overturn verdicts)
- Schneider v. Fried, 320 F.3d 396 (3d Cir. 2003) (Rule 702 sets standards for expert testimony: qualification, reliability, fit)
- In re Paoli R.R. Yard PCB Litig., 35 F.3d 717 (3d Cir. 1994) (reliability of expert testimony under Daubert)