SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical LTD

CourtDistrict Court, W.D. Wisconsin
DecidedApril 21, 2025
Docket3:20-cv-00019
StatusUnknown

This text of SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical LTD (SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical LTD) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical LTD, (W.D. Wis. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

SSI TECHNOLOGIES, LLC,

Plaintiff, v. OPINION and ORDER

DONGGUAN ZHENGYANG ELECTRONIC 20-cv-19-jdp MECHANICAL LTD,

Defendant.

Plaintiff SSI Technologies, LLC has prevailed in a patent infringement suit against defendant Dongguan Zhengyang Electronic Mechanical LTD (DZEM). The background to the technology and the full procedural history of the case are in two of the court’s previous summary judgment orders. Dkt. 199; Dkt. 239. The background that matters most for this order is that the court ruled on summary judgment that DZEM infringed the ’038 patent and damages and willfulness were tried to a jury. The jury found DZEM’s infringement to be willful during two periods and awarded damages of approximately $16.6 million. Post-trial motions are now before the court. ANALYSIS A. DZEM’s motion for judgment as a matter of law or for new trial DZEM moves for judgment as a matter of law on three bases: (1) the jury’s finding of willfulness is not supported by evidence; (2) there was no evidence to support the jury’s inclusion of sales to PACCAR among infringing sales; and (3) there was no evidence to support the jury’s award of lost profits. Alternatively, DZEM moves for a new trial based on several of the court’s evidentiary rulings. On a motion for judgment as a matter of law under Rule 50(b), the question is whether the evidence, and reasonable inferences drawn from it, supports the verdict. EEOC v. AutoZone, Inc., 707 F.3d 824, 835 (7th Cir. 2013). The court views the evidence in the light most favorable to the prevailing party, here SSI. Passananti v. Cook County, 689 F.3d 655, 659 (7th

Cir. 2012). The court may not reweigh the evidence or make credibility determinations, and it does not consider evidence favorable to the moving party that the jury was not required to believe. Id. The court may grant DZEM’s motion only if no rational jury could have found for SSI. Id. The court may grant a motion for a new trial under Rule 59(a) if the verdict is “against the manifest weight of the evidence or if the trial was in some way unfair to the moving party.” Lewis v. McLean, 941 F.3d 886, 891 (7th Cir. 2019). A verdict is contrary to the manifest weight of the evidence only if no rational jury could have rendered the verdict. Willis v. Lepine, 687

F.3d 826, 836 (7th Cir. 2012). The court should order a new trial only if the record shows the jury’s verdict “resulted in a miscarriage of justice or where the verdict, on the record, cries out to be overturned or shocks [the] conscience.” Davis v. Wis. Dep’t of Corr., 445 F.3d 971, 979 (7th Cir. 2006) (citation omitted). As under Rule 50, the court does not make credibility determinations or weigh the evidence. Whitehead v. Bond, 680 F.3d 919, 925 (7th Cir. 2012). Willfulness The willfulness inquiry is framed by two decisions of this court. This court held on

September 3, 2021, that DZEM did not infringe the ’038 patent. Dkt. 199. The Federal Circuit reversed that decision and remanded the case. The court then decided on May 23, 2024, based primarily on the Federal Circuit’s interpretation of the term “filter,” that DZEM did infringe the ’038 patent. Dkt. 239. The jury found that DZEM’s infringement was willful both before and after the two decisions by this court. Accordingly, the jury found DZEM’s infringement to be willful during two periods: from January 2019 to September 3, 2021, and from May 23, 2024 to the date of the trial. a. Willfulness from January 2019 to September 3, 2021

DZEM’s core argument is that during this first period, it had a reasonable, good-faith belief that it did not infringe the ’038 patent based on its claim construction of the term “filter.” The reasonableness of that position, so the argument goes, is confirmed by this court’s adoption of that interpretation in the first summary judgment decision. DZEM cites trial testimony from Snow Mei and Ernie Huang to support DZEM’s good-faith belief. There are several problems with DZEM’s argument. First, the court’s first summary judgment opinion says nothing about the state of mind

of DZEM’s personnel during the relevant period. Willfulness is judged by the state of mind of the infringer at the time of the infringement. Halo Elecs., Inc. v. Pulse Elecs., Inc., 579 U.S. 93, 105 (2016). The efforts and imagination of trial counsel do not spare a defendant from a finding that its prior infringement was willful. The second problem is the jury did not have to believe either Mei or Huang’s testimony that they believed that DZEM’s sensor did not infringe the ’038 patent. The third problem is that the jury heard evidence that DZEM had misled its customers about the risk of infringement of the ’038 patent. DZEM was aware of the ’038 patent by

2017. In 2018, DZEM commissioned freedom-to-operate opinions from two United States law firms. But DZEM did not inform those law firms of the ’038 patent. The jury could infer from this failure to disclose that DZEM personnel intended to suppress information about potential infringement. But there’s more. Shortly after filing this suit, SSI sent warning letters to DZEM customers. Those customers turned to DZEM for explanation. DZEM expressed to its customers that it determined after an investigation that its sensor did not infringe the ’038 patent. For example, Huang’s email to DTNA said “[DZEM] is convinced that there [is] no evidence that our rubber cover infringes the complainant’s patent. Our legal counsel has on

multiple occasion[s] shared our analysis, position, and requested additional information from SSI.” Trial Ex. 46. Huang included with his email an attachment that said: To further confirm our patents’ uniqueness [DZEM] requested in 2018 two USA law-firms to separately investigate and validate that we could obtain a Freedom to Operate (FTO). During this study the patent attorneys performed a global search seeking any possible patent issues related to our urea sending unit, including the ultrasonic quality sensor. It was found during the search that our sensor had “Freedom to Operate” meaning that the patent attorneys did not find any evidence of patent infringement. Id. But Huang did not disclose to DTNA that the 2018 freedom-to-operate opinion did not actually consider the ’038 patent, even though DZEM was aware of it when it commissioned the opinion. A reasonable jury could find that DZEM’s response to its worried customers was dishonest, and that DZEM was aware of, or willfully blind to, the risk of infringement. DZEM contends that Huang’s email was intended only to communicate that DZEM had its own patents on its sensor. But that spin is not consistent with the text of the attachment to Huang’s email. At the very least, a reasonable jury could infer that Huang’s purpose in citing the 2018 freedom-to-operate opinion was to persuade DTNA that its non-infringement position was supported by the legal analysis of two United States law firms, but that was not true. The fourth problem is that the jury heard circumstantial evidence of copying. DZEM gained access to SSI’s technology through meetings over a potential joint venture, acquired an SSI sensor, and thereafter redesigned its sensor to include the rubber cover with a bubble-reduction filter. DZEM’s rubber cover is not a literal copy of SSI’s cover. But a

reasonable jury could find that DZEM incorporated the filter and chimney arrangement from SSI’s product.

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SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical LTD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ssi-technologies-llc-v-dongguan-zhengyang-electronic-mechanical-ltd-wiwd-2025.