Ateliers de la Haute-Garonne v. Broetje Automation-USA Inc.

85 F. Supp. 3d 768, 2015 U.S. Dist. LEXIS 39850, 2015 WL 1467204
CourtDistrict Court, D. Delaware
DecidedMarch 30, 2015
DocketCivil Action No. 09-598-LPS
StatusPublished
Cited by17 cases

This text of 85 F. Supp. 3d 768 (Ateliers de la Haute-Garonne v. Broetje Automation-USA Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ateliers de la Haute-Garonne v. Broetje Automation-USA Inc., 85 F. Supp. 3d 768, 2015 U.S. Dist. LEXIS 39850, 2015 WL 1467204 (D. Del. 2015).

Opinion

MEMORANDUM OPINION

STARK, District Judge:

Pending before the Court is Ateliers de la Haute-Garonne and F2C2 Systems S.A.S.’s (collectively, “AHG’s”) Motion for Attorneys’ Fees (D.I.426), Broetje Automation-USA Inc. and Brotje Automation GMBH’s (collectively, “Broetje’s”) Combined Renewed Motion for Judgment as a Matter of Law (“JMOL”), or, in the alternative, for a New Trial, or to Alter and Amend the Judgment (D.I.434), and AHG’s Motion to Alter or Amend the Judgment (D.I.441).

I. BACKGROUND

AHG filed this patent infringement action on May 12, 2009, alleging that Broetje infringes United States Patent Nos. 5,011,-339, (“the ’339 patent”) and 5,143,216 (“the ’216 patent”). (D.I. 2; see also D.I. 48) With respect to the ’339 patent, AHG asserted infringement of claims 1, 2, and 6, and with respect to the ’216 patent, infringement of claims 1 and 2. AHG also accused Broetje of trade dress infringement, unfair competition, and violation of [774]*774California law against intentional interference with prospective economic advantage (“IIPEA”). (D.I. 48 at ¶¶ 53-96)

The Court presided over a five-day jury trial in April 2014. (See D.I. 416) On the patent issues, the jury found that Broetje directly, contributorily, and willfully infringed both the ’339 and ’216 patents and that it induced infringement as well. The jury determined that the asserted claims in the ’339 and ’216 patents were valid. The jury further found that Broetje intentionally infringed AHG’s trade dress, which — by the parties’ stipulation — also made Broetje liable for unfair competition. The jury additionally found that Broetje intentionally interfered with AHG’s prospective economic advantage in violation of California law. The jury awarded AHG $2,099,943 in compensatory damages for patent infringement, $6,000,000 in compensatory damages for trade dress infringement, unfair competition, and IIEPA, and an additional $6,000,000 of punitive damages for intentional trade dress infringement, intentional unfair competition, and IIEPA, for a total award of $14,099,943. (D.I.416) •

The Court entered judgment on the verdict on April 28, 2014. (D.I.425) The parties filed post-trial motions and completed briefing on July 11, 2014. (See D.I. 470) The Court heard argument on the motions on September 15, 2014. (See D.I. 482)

At the conclusion of the motions hearing, the Court advised the parties it was prepared to share its inclinations on the issues in dispute, but would solicit the parties’ views on whether it should do so. (Id. at 83-86) As the Court explained, what was motivating its proposal to share its inclinations was its sense that this longstanding case (which has already been to the Federal Circuit and back once before) was either going to be litigated for a long time to come or the parties were going to work out a resolution acceptable to both sides. (See id.) When the parties were unable to agree even on whether the Court should share its inclinations, the Court decided it would do so nonetheless. (D.I.484) In an October 22, 2014 letter to counsel, “in hopes that there may yet be an opportunity for the parties to resolve this case without further litigation, and that perhaps I may spare the parties additional effort and expense, I have decided to tell you how I am likely to decide the motions.” (Id. at 1) Specifically, the Court stated that, among other things, it was inclined to deny AHG’s motion for attorney fees, deny Broetje’s motion for a new trial, and grant in part and deny in part Broetje’s motion for judgment as a matter of law. (Id. at 2)1

II. LEGAL STANDARDS

A. Motion for Judgment as a Matter of Law

Judgment as a matter of law is appropriate if “the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for [a] party” on an issue. Fed.R.Civ.P. 50(a)(1). “Entry of judgment as a matter of law is a sparingly invoked remedy,” one “granted only if, viewing the evidence in the light most favorable to the nonmovant and giving it the advantage of every fair and [775]*775reasonable inference, there is insufficient evidence from which a jury reasonably could find liability.” Marra v. Phila. Hous. Auth., 497 F.3d 286, 300 (3d Cir.2007) (internal quotation marks omitted).

To prevail on a renewed motion for judgment as a matter of law following a jury trial, the moving party “must show that the jury’s findings, presumed or express, are not supported by substantial evidence or, if they were, that the legal conclusions implied [by] the jury’s verdict cannot in law be supported by those findings.” Pannu v. Iolab Corp., 155 F.3d 1344, 1348 (Fed.Cir.1998) (internal quotation marks omitted). “ ‘Substantial’ evidence is such relevant evidence from the record taken as a whole as might be accepted by a reasonable mind as adequate to support the finding under review.” Perkin-Elmer Corp. v. Computervision Corp., 732 F.2d 888, 893 (Fed.Cir.1984).

In assessing the sufficiency of the evidence, the Court must give the non-moving party, “as [the] verdict winner, the benefit of all logical inferences that could be drawn from the evidence presented, resolve all conflicts in the evidence in his favor, and in general, view the record in the light most favorable to him.” Williamson v. Consol. Rail Corp., 926 F.2d 1344, 1348 (3d Cir.1991); see also Perkin-Elmer Corp., 732 F.2d at 893. The Court may not assess the credibility of witnesses nor “substitute its choice for that of the jury between conflicting elements of the evidence.” Perkin-Elmer Corp., 732 F.2d at 893. Rather, the Court must determine whether the evidence reasonably supports the jury’s verdict. See Dawn Equip. Co. v. Ky. Farms Inc., 140 F.3d 1009, 1014 (Fed.Cir.1998); Gomez v. Allegheny Health Servs. Inc., 71 F.3d 1079, 1083 (3d Cir.1995) (describing standard as “whether there is evidence upon which a reasonable jury could properly have found its verdict”); 9B Wright & Miller, Federal Practice & Procedure § 2524 (3d ed. 2008) (“The question is not whether there is literally no evidence supporting the party against whom the motion is directed but whether there is evidence upon which the jury properly could find a verdict for that party.”).

B. Motion for a New Trial

Federal Rule of Civil Procedure 59(a) provides, in pertinent part:

A new trial may be granted to all or any of the parties and on all or part of the issues in an action in which there has been a trial by jury, for any of the reasons for which new trials have heretofore been granted in actions at law in the courts of the United States.

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85 F. Supp. 3d 768, 2015 U.S. Dist. LEXIS 39850, 2015 WL 1467204, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ateliers-de-la-haute-garonne-v-broetje-automation-usa-inc-ded-2015.