Nike, Inc. v. lululemon usa inc.

CourtDistrict Court, S.D. New York
DecidedMarch 31, 2026
Docket1:23-cv-00771
StatusUnknown

This text of Nike, Inc. v. lululemon usa inc. (Nike, Inc. v. lululemon usa 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
Nike, Inc. v. lululemon usa inc., (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Nike, Inc., Plaintiff, 23-cv-771 (AS) -against-

lululemon usa inc., OPINION AND ORDER Defendant.

ARUN SUBRAMANIAN, United States District Judge: The motions before the Court arise from a patent infringement trial. Nike, the holder of two patents related to shoes, sued lululemon for selling shoes that allegedly infringed its patents. The jury returned a verdict for Nike on one of the two patents—the ’749— awarding $355,450 in dam- ages. Dkt. 314. Mutually dissatisfied with that outcome, both sides filed post-trial motions with respect to the ’749 patent that the jury found was infringed. Nike wants to get more money—it asks the Court (1) to amend the judgment to include supplemental damages and interest and (2) for judgment as a matter of law on pre-suit damages (and in the alternative, a new trial on the question). Fed. R. Civ. P. 59(e), 50(b), 59(a)(1). lululemon, wants to throw away the verdict en- tirely—it asks the Court for (1) judgment as matter of law on whether the asserted claims of the ’749 patent are invalid for obviousness and, in the alternative, (2) a new trial based on alleged violations of the Court’s holdings on the motions in limine. Fed. R. Civ. P. 50, 59. lululemon’s motion for judgment as a matter of law is GRANTED. All other motions are DE- NIED as moot. BACKGROUND Nike holds patents in techniques for creating the textiles that are used in sneakers. At issue here is a patent that describes how a large textile is knitted with parts that can be cut out and used as the “uppers” of sneakers: the ’749 patent. The parts used to make the uppers are textured through a knitting process called “warp knitting,” in which a large textile and parts that are cut out and used for the uppers are knitted all at the same time (more on this later). lululemon sold shoes that use this process. Nike sued. At trial, lululemon argued that Nike’s patent was invalid because it’s obvious and that lu- lulemon didn’t control the factories where the shoes were made, so it wouldn’t owe pre-suit dam- ages. To show that the method would be obvious to a person of ordinary skill in the art, lululemon presented two examples of shoes made by adidas that it said used the same technique before Nike ever filed its patent, as well as other examples of knitted items using similar techniques. And to show that it didn’t control the factories, lululemon pointed to the complexities of its production chain, which involved upstream industry participants that it had no contact with. At the close of trial, both sides moved under Rule 50(a) for judgment as a matter of law. Tr. 871–84. The Court reserved judgment and the case went to the jury. Tr. 884:23. The jury found that lululemon infringed the ’749 patent but that it hadn’t controlled its manu- facturers and so had to pay only a lower sum: $355,450. Dkts. 314 at 5; 319. Now, both sides have filed post-trial motions. Nike’s motions ask for greater damages or interest; lululemon’s for either judgment as a matter of law on the validity of the ’749 patent or a new trial. lululemon’s motion for judgment as a matter of law presents a threshold issue to reaching any of the other questions. If Nike’s patent is invalid because it’s obvious, then every other issue is moot. LEGAL STANDARDS Cases involving patents are governed by a mix of law from the regional circuit and the Federal Circuit. “[I]ssues of substantive patent law and certain procedural issues pertaining to patent law” are governed by Federal Circuit precedent, but “the law of the regional circuits” applies “on non- patent issues.” Utah Med. Prods., Inc. v. Graphic Controls Corp., 350 F.3d 1376, 1381 (Fed. Cir. 2003). Post-trial motions are analyzed “under regional circuit law, the Second Circuit in this case.” Whitserve, LCC v. Comput. Packages, Inc., 694 F.3d 10, 18 (Fed. Cir. 2012). To grant a motion for judgment as a matter of law under Federal Rule of Civil Procedure 50, “the Court must find that a reasonable jury would not have a legally sufficient evidentiary basis to find for the non-movant.” Perry v. City of New York, 78 F.4th 502, 517 (2d Cir. 2023) (cleaned up). That is, the Court must deny the motion “unless there is 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.” Id. (citation omitted). “The burden on the movant is particularly heavy where, as here, the jury has deliberated in the case and actually re- turned its verdict.” Id. (internal quotation marks omitted). In evaluating the Rule 50 motion, the Court “consider[s] the evidence in the light most favor- able to the non-moving party and give[s] that party the benefit of all reasonable inferences that the jury might have drawn in that party’s favor.” Id. (cleaned up). “The court cannot assess the weight of conflicting evidence, pass on the credibility of the witnesses, or substitute its judgment for that of the jury, and must disregard all evidence favorable to the moving party that the jury is not required to believe.” ING Glob. v. United Parcel Serv. Oasis Supply Corp., 757 F.3d 92, 97 (2d Cir. 2014) (internal quotation marks omitted). DISCUSSION I. Nike waived any argument that lululemon’s challenge was not preserved Before proceeding, the Court cleans up a procedural tangle. When lululemon orally made its 50(a) motions it clearly did so on a few grounds: infringement, pre-suit damages, and damages more generally. Tr. 874–81. But counsel for lululemon didn’t mention validity or obviousness, except in response to Nike’s Rule 50 motion on validity. There, after noting that “I think that would be our affirmative motions,” counsel for lululemon added “one last thing, if I am going to respond” and proceeded to address validity. Tr. 881:13–16. Counsel proceeded to explain that lululemon had introduced “sufficient evidence in the record to conclude that” the patent claims were obvious. Tr. 882:7–9. But “sufficient evidence in the record” is an argument that the other side—here, Nike—isn’t entitled to judgment as a matter of law, not that the party pointing to that evidence— lululemon—should itself get such relief. That might have been a silver bullet argument for Nike. After all, “the grounds on which a party may rely in a Rule 50(b) motion are limited to those grounds that were specifically raised in the prior Rule 50(a) motion.” Ojeda v. MTA, 477 F. Supp. 3d 65, 73 (S.D.N.Y. 2020) (cleaned up) (quoting Galdieri-Ambrosini v. Nat’l Realty & Dev. Corp., 136 F.3d 276, 286 (2d Cir. 1998)). But just as a party can fail to preserve an argument, so too can the opposing party waive its argument against preservation. Gronwoski v. Spencer, 424 F.3d 285, 297 (2d Cir.

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Nike, Inc. v. lululemon usa inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/nike-inc-v-lululemon-usa-inc-nysd-2026.