Synqor, Inc. v. Artesyn Technologies, Inc.
709 F.3d 1365
| Fed. Cir. | 2013Background
- This case involves SynQor’s patent infringement claims against nine power-converter manufacturers (over DC-DC converters) and related asserted claims from the ’190, ’021, ’702, ’083, and ’034 patents.
- The district court granted partial summary judgment finding infringement for certain isolation-related limitations and substantial damages after a jury trial.
- The patented system uses a multi-stage distributed architecture with a non-regulating isolation stage followed by non-isolating regulation stages (IBA).
- The district court denied JMOLs and new trials, and later awarded supplemental damages, enhanced damages for post-verdict infringement, and sanctions for discovery violations.
- On appeal, the Federal Circuit reviews claim construction, anticipation/obviousness, entitlement to priority, induced/contributory infringement, and damages awards for reasonableness and support by the record.
- The court ultimately affirms the district court’s judgment with respect to the infringement findings, invalidity/obviousness determinations, and damages rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Anticipation/obviousness of plurality of non-isolating regulators | Mweene Thesis anticipates/teaches elements | Mweene + Mammano renders obvious | Not anticipated/obvious; sufficient evidence supports non-anticipation. |
| Claim 1 of the 083 Patent and Mweene disclosure | Mweene discloses parallel rectifiers and conductance | Mweene shows disclosure of the claimed configuration | Not anticipated; jury findings supported by evidence. |
| Claim 9 of the 034 Patent validity/priority | Arduini teaches a related DC-DC system but not the claimed combination | Arduini/priority prior art anticipates/undermines priority date | Not invalid for anticipation/obviousness; 1998 priority properly supported. |
| District court’s isolation construction | Isolation must be between input and output of entire system | Isolation between two points elsewhere | Correct; isolation requires absence of an electrical path between input and output of a particular stage. |
| Knowledge for induced/contributory infringement | Actual knowledge of the patents existed; instructing jury accordingly | Instruction misleading about knowledge; insufficient evidence of pre-suit knowledge | jury instructions, taken as a whole, conveyed actual knowledge; substantial evidence supported pre-suit knowledge; JMOL affirmed against noninfringement. |
Key Cases Cited
- Connell v. Sears, Roebuck & Co., 722 F.2d 1542 (Fed. Cir. 1983) (anticipation requires all elements in one disclosure)
- Therasense, Inc. v. Becton, Dickinson & Co., 563 F.3d 1275 (Fed. Cir. 2010) (clear and convincing standard for obviousness, and wealth of factual questions)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claims should be given their ordinary meaning in context)
- Agrizap, Inc. v. Woodstream Corp., 520 F.3d 1337 (Fed. Cir. 2008) (evidentiary standards for damages and nexus of evidence)
- Crystal Semiconductor Corp. v. TriTech Microelectronics Int’l, Inc., 246 F.3d 1336 (Fed. Cir. 2001) (but-for damages analysis requires consideration of demand and alternatives)