TQ Delta, LLC v. CommScope Holding Company, Inc.
2:21-cv-00310
E.D. Tex.Sep 3, 2024Background
- TQ Delta sued CommScope and related entities for patent infringement resulting in a May 2023 judgment.
- The jury awarded TQ Delta $11,125,000 in reasonable royalty damages plus prejudgment interest, post-judgment interest, and litigation costs.
- The court ordered costs of $246,208.25 to be paid to TQ Delta, and a first deposit of $11,371,208.25 was made to the court's registry by Vantiva SA for Defendants.
- The dispute revolves around the proper calculation and accrual date for prejudgment interest on the damages award.
- TQ Delta sought interest from the date the first asserted patent issued (November 18, 2008), while Defendants argued interest could only accrue from six years before the complaint was filed (August 13, 2015), per § 286.
- The court needed to resolve this issue to determine the correct total amount of funds Defendants must place in the court's registry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When does prejudgment interest begin accruing? | From the date of first asserted patent (Nov. 18, 2008); aligns with hypothetical negotiation | From six years before complaint filing per § 286 (Aug. 13, 2015) | Prejudgment interest accrues from Aug. 13, 2015 |
| Scope of § 286 on prejudgment interest | § 286 does not limit period for prejudgment interest accrual | § 286 restricts damages and thus prejudgment interest accrual period | § 286 bars interest before Aug. 13, 2015 |
| Effect of lump sum vs. running royalty award | Lump sum should trigger interest from hypothetical negotiation date | Method of damages does not affect § 286's time limitation | No distinction; § 286 applies to both types |
| Final Judgment's meaning of 'date of infringement' | 'Date of infringement' is hypothetical negotiation date | 'Date of infringement' is the actionable damages period under § 286 | It refers to the damages period, not hypothetical negotiation |
Key Cases Cited
- General Motors Corp. v. Devex Corp., 461 U.S. 648 (prejudgment interest should ordinarily be awarded to fully compensate for infringement)
- Sensonics, Inc. v. Aerosonic Corp., 81 F.3d 1566 (prejudgment interest intended to make patent owner whole, not to penalize)
- Bio-Rad Labs., Inc. v. Nicolet Instrument Corp., 807 F.2d 964 (prejudgment interest should run from date of infringement to judgment)
- Nickson Indus., Inc. v. Rol Mfg. Co., 847 F.2d 795 (interest typically awarded from first infringement to judgment)