J.R. Simplot Company v. McCain Foods USA, Inc.

District Court, D. Idaho·Decided August 13, 2024·No. 1:16-cv-00449·Unknown

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

J.R. SIMPLOT COMPANY, Case No. 1:16-cv-00449-DCN1 Plaintiff, MEMORANDUM DECISION AND v. ORDER

McCAIN FOODS USA, INC.,

Defendant. _________________________________

McCAIN FOODS LIMITED,

Plaintiff,

v.

J.R. SIMPLOT COMPANY,

Defendant.

I. INTRODUCTION Before the Court are various pretrial matters. The Court recently issued a decision regarding the parties’ formal motions in limine and a large dispute about how trial will proceed. Dkt. 536.2 However, there are numerous other evidentiary matters, objections,

1 This case involves additional parties—namely Elea Vertriebs-und-Vermarktungsgesellschaft, mbH, and Food Physics LLC. However, because the impending trial does not involve those parties, the Court has removed them from the case caption for simplicity.

2 A recently filed Motion in Limine from McCain is still outstanding. Dkt. 537. and disagreements that require the Court’s attention. The Court resolves some of them with this Order. Motions in limine are designed to streamline trial by settling, in advance, any

evidentiary disputes. See United States v. Tokash, 282 F.3d 962, 968 (7th Cir. 2002)). The Court has wide discretion in ruling on such motions, see United States v. Ravel, 930 F.2d 721, 726 (9th Cir. 1991), and the Court can alter or amend any rulings at trial should the evidence or testimony warrant a change. See Ohler v. United States, 529 U.S. 753, 758 n.3 (2000).

II. DISCUSSION3 A. Damages / Disgorgement McCain believes the issue of any remedy in this case is equitable and should be decided by the Court, not the jury. Dkt. 491, at 17–18. For this reason, it objects to certain language Simplot has included in its proposed voir dire and proposed jury instructions.

And while not spelled out, implicitly included in this objection concerning potential language is an objection regarding the introduction of evidence and testimony about damages in the first instance. Also, McCain prefers the word “remedy” to “damages.” McCain and Simplot have elected to seek the others’ profits under 35 U.S.C. § 289 as the measure of infringement damages in this trial. 35 U.S.C. § 289 is titled “Additional

remedy for infringement of design patent.”

3 For brevity, and due to time constraints, the Court will not reiterate each sides’ arguments at great length. The Court will also forgo any background regarding the case itself or the patents at issue assuming the readers’ familiarity with the same. For more background, see Dkt. 474, at 3–7; Dkt. 536, at 2–4. McCain points out that the Federal Circuit has held, “if the patentee seeks only equitable relief, the accused infringer has no right to a jury trial.” In re Tech. Licensing Corp., 423 F.3d 1286, 1290–91 (Fed. Cir. 2005). Citing two out-of-circuit district court

cases4 that held a claim for damages under § 289 to be equitable, McCain postures that the damages portion of trial—assuming it even occurs—should be in front of the Court, not the jury.5 Simplot responds with another Federal Circuit case, Catalina Lighting, Inc. v. Lamps Plus, Inc., 295 F.3d 1277, 1290 (Fed. Cir. 2002), wherein a jury award under § 289

was affirmed. It also cites two inter-circuit district court cases where juries determined damages under § 289.6 Notably, one of those district cases—Columbia Sportswear—was appealed. As part of the appellate decision, the Federal Circuit reviewed the jury award for damages. To be sure, the Federal Circuit did not come out and say who—the Court or a jury—must determine damages under § 289. But the circuit also did not comment (or even

hint) that using a jury was improper. Columbia Sportswear N. Am., Inc. v. Seirus Innovative Accessories, Inc., 80 F.4th 1363 (Fed. Cir. 2023), cert. denied, 2024 WL 2262346 (U.S. May 20, 2024). At the very least, Simplot suggests the Court can send the question to the

4 Shure Inc. v. ClearOne, Inc., 2021 WL 4991083, at *1 (D. Del. Oct. 27, 2021) (holding that “disgorgement is an equitable remedy”); Red Carpet Studios v. Midwest Trading Grp., Inc., 2021 WL 1172218, at *2 (S.D. Ohio Mar. 29, 2021) (“[A] claim for damages under § 289 is one for equitable relief.”). 5 Notably, other Courts disagree. See,e.g., Kitsch LLC v. Deejayzoo, LLC, 2023 WL 4291445, at *3 (C.D. Cal. May 8, 2023) (holding there was “insufficient authority to support the contention that disgorgement of profits from design patent infringement under 35 U.S.C. § 289 presents a purely equitable issue”). 6 Apple Inc. v. Samsung Elecs., 2018 WL 1586276 (N.D. Cal. Apr. 2, 2018) (giving the question of damages to the jury in a design patent case); Columbia Sportswear N. Am. Inc. v. Seirus Innovative Accessories, Inc., 2018 WL 1805102 (S.D Cal. Apr. 17, 2018) (jury awarding over $3 million under 35 U.S.C. § 289). jury in an advisory capacity under Rule 39.7 While there are cases indicating that disgorgement of profits is an equitable remedy, there are also cases indicating it is not. Additionally, there is authority from the Federal

Circuit supporting—albeit implicitly—the idea that the question of damages under § 289 can be presented to a jury for consideration. Thus, without formally deciding the matter, the Court finds that sending the question of damages to the jury in this case is proper. And from a judicial economy standpoint, following such a procedure makes the most sense because both the Court and the jury will hear the relevant testimony. Thus, even

if the Court then finds some reason to set aside the jury’s award (or a higher court rules the jury award should not be considered), the Court will not have to rehear the evidence and testimony; it can simply decide. And the opposite is even more important: if the Court were to excuse the jury and decide the issue itself, and then change its mind (or if a higher court were to rule the jury should have decided the matter), then the Court would have to

reconvene the prior jury or empanel a whole new jury. Thus, all things considered, the more economical thing to do is send the issue to a jury.8 At a minimum, the jury’s determination could be advisory. Assuming infringement (and no invalidity) is found, the issue of disgorgement will be evaluated by a jury. As far as what to call it, the Court does not see a material difference

7 Federal Rule of Civil Procedure 39(c)(1) outlines that, “in an action not triable of right by a jury, the court, on motion or its own may try any issue with an advisory jury”).

8 This is consistent with Rule 1 of the Federal Rules of Civil Procedure

Free access — add to your briefcase to read the full text and ask questions with AI

J.R. Simplot Company v. McCain Foods USA, Inc., (D. Idaho 2024).

J.R. Simplot Company v. McCain Foods USA, Inc. (J.R. Simplot Company v. McCain Foods USA, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related