Geigtech East Bay LLC v. Lutron Electronics Co., Inc.

CourtDistrict Court, S.D. New York
DecidedJune 4, 2025
Docket1:18-cv-05290
StatusUnknown

This text of Geigtech East Bay LLC v. Lutron Electronics Co., Inc. (Geigtech East Bay LLC v. Lutron Electronics Co., Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Geigtech East Bay LLC v. Lutron Electronics Co., Inc., (S.D.N.Y. 2025).

Opinion

é ee cmsannanannt □□□□ - |, USDC SDNY □ DOCUMEN UNITED STATES DISTRICT COURT So □□ ELECTRONICATLY FILED |] SOUTHERN DISTRICT OF NEW YORK □□ X DOCH i| |} DATEFILED: GEIGTECH EAST BAY LLC, ———— ae Plaintiff, 18 Civ. 05290 (CM) -against- 19 Civ. 04693 (CM) 20 Civ. 10195 (CM) LUTRON ELECTRONICS CO., INC., Defendant. ee DECISION AND ORDER McMahon, J.: This opinion addresses the two remaining post-trial motions that are pending in this case: (i) Lutron’s Motion for Judgment as a Matter of Law on damages and (ii) GeigTech’s Motion for Enhanced Damages, Interests, and Costs. Dkt. Nos. 590; 587. After two trials and many opinions over the past seven years, the Court assumed familiarity with the facts and major players involved in this case. I. Lutron’s Motion for Judgment as a Matter of Law At the close of GeigTech’s case in chief, Lutron moved for, and renewed at the close of all evidence, judgment as a matter of law under Fed. R. Civ. P. 50(a). In its motion, Lutron argued that GeigTech had not met its burden to support a jury verdict that calculated damages via the entire market value rule (“EMVR”). See Tr. 289; 466. I reserved judgment on the motion, leaving the issue open until the jury had the opportunity to determine what a reasonable royalty in this case would be. Tr. 466. Lutron now seeks the same relief under Fed. R. Civ. P. 50(a) and 50(b). See Dkt. No. 590.

During closing statements, the two parties reiterated their opposing positions on what a reasonable royalty should be: Lutron asked the jury to award $398,706 and GeigTech asked the jury to award $4,054,302. Tr. 504; 522. After deliberations, the jury followed neither recommendation and returned a verdict awarding GeigTech $2,672,000. Tr. 551. What I said at the time remains as true now as it was then: “One might say they think you’re all unreasonable,

and who am I to quarrel with that.” Tr. 553. a. Legal Standard Judgment as a matter of law may be entered against a party only if “a reasonable jury would not have a legally sufficient basis to find for [a] party on that issue.” Fed. R. Civ. P. 50(a). A Rule 50 motion may only be granted “if there exists such a complete absence of evidence supporting the verdict that the jury’s findings could only have been the result of sheer surmise and conjecture, or the evidence in favor of the movant is so overwhelming that reasonable and fair minded [persons] could not arrive at a verdict against [it].” Tepperwien v. Entergy Nuclear Operations, Inc., 663 F.3d 556, 567 (2d Cir. 2011) (quoting Brady v. Wal-Mart Stores, Inc., 531 F.3d 127, 133

(2d Cir. 2008) (alterations in original)). “In assessing the sufficiency of evidence to support a jury verdict, [the Court] must view the record in the light most favorable to the opposing party, assuming all reasonable inferences were drawn and all credibility disputes resolved in its favor.” Advance Pharm., Inc. v. United States, 391 F.3d 377, 390 (2d Cir. 2004). The two categories of compensation for patent infringement are a patentee’s lost profits and the “reasonable royalty he would have received through arms-length bargaining.” Lucent Techs., Inc. v. Gateway, Inc., 580 F.3d 1301, 1324 (Fed. Cir. 2009). The only measure of damages sought in this case was a reasonable royalty, which “seeks to compensate the patentee . . . for its lost opportunity to obtain a reasonable royalty that the infringer would have been willing to pay if it had been barred from infringing.” AstraZeneca A13 v. Apotex Corp., 782 F.3d 1324, 1334 (Fed. Cir. 2015) (citing Lucent Techs., 580 F.3d at 1325). GeigTech did not seek lost profits damages. It argued to the jury that the only measure of its damages was a reasonable royalty. And the Court instructed the jury accordingly: [A] reasonable royalty is not measured by the profits that GeigTech may have lost as a result of Lutron’s infringement. It’s not measured by the expenses that GeigTech incurred as a result of the infringement. And a reasonable royalty is never punitive; it’s not intended to punish Lutron for infringing the patent. A reasonable royalty reflects a business deal that would have been agreed upon by rational businesspeople. It represents the amount that a purchaser of a license who wanted to use a patented technology and to make a profit would have been willing to pay to the owner of the patented technology who wanted to license the patent to some third party.

Tr. 538-39. As an exception to the general rule that royalties are awarded based on the smallest salable patent-practicing unit, a patentee may also seek to recover under the “entire market value” theory of damages. Under this theory, a patentee may base its royalties on the entire value of the patented article “where the patented feature creates the ‘basis for customer demand’ or ‘substantially create[s] the value of the component parts.’” Uniloc USA, Inc. v. Microsoft Corp., 632 F.3d 1292, 1318 (Fed. Cir. 2011). The Federal Circuit has sustained recovery under this theory when “the invention inextricably worked with outer components of [the product] as a single functioning unit . . . improved the performance . . contributed substantially to the increased demand . . . [and] was integral to the overall performance” of the product. Bose Corp. v. JBL, Inc., 274 F.3d 1354, 1361 (Fed. Cir. 2001). The Federal Circuit reiterated that conclusion where “[t]he evidence at trial portrayed general industry demand for” a certain type of product (e.g., aesthetically pleasing exposed shade brackets) and “the patented technology furthers these goals.” Funai Elec. Co., Ltd. v. Daewoo Elecs. Corp., 616 F.3d 1357, 1375 (Fed. Cir. 2010). b. GeigTech Presented Sufficient Evidence from Which a Jury Could Calculate a Reasonable Royalty of $2,672,000.

At trial, both sides offered proposed damages calculations. GeigTech’s expert, Mr. Jeffrey Baliban, testified that he calculated a reasonable royalty to be $4,052,302, while Lutron’s expert, Dr. Christine Meyer, testified that she calculated a reasonably royalty to be around $400,000. Tr. 276-77; 428. The jury returned a verdict of $2,672,000. Lutron’s argument on its 50(a) motion proceeds as follows: (i) “the Court instructed that it was GeigTech’s burden to prove that the ‘717 Patent was the sole driving factor for customers’ demand for the Palladiom Wired Shading System;” (Dkt. No. 591, at 8); (ii) “‘working the math backwards’ suggests that the jury, in spite of not indicating so on the verdict form, improperly applied EMVR;” id. at 9; and (iii) GeigTech failed to provide sufficient evidence to justify the application of the EMVR; id. at 8. Therefore, Lutron argues, I should overturn the jury’s verdict. My charge was not so limited as Lutron implies.

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Bluebook (online)
Geigtech East Bay LLC v. Lutron Electronics Co., Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/geigtech-east-bay-llc-v-lutron-electronics-co-inc-nysd-2025.