Judge Stark issues opinions on post-trial motions in latest dispute between Power Integrations and Fairchild Semiconductor
Judge Stark recently considered the parties’ post-trial motions following a jury trial in the long-standing dispute between Power Integrations and Fairchild Semiconductor. Power Integrations, Inc. v. Fairchild Semiconductor International Inc., et al., C.A. No. 08-309-LPS (D. Del. Mar. 29, 2013). The case involved infringement allegations by both the plaintiff and the defendants involving a total of six patents related to DC output power supplies or power converters. Regarding Power‘s U.S. Patent No. 6,249,876, the jury found that Fairchild infringed, literally and under the doctrine of equivalents, induced infringement and that the asserted claims were valid. Id. at 2. Regarding U.S. Patent No. 6,107,851, “the jury found in favor of Power and against Fairchild with respect to literal infringement, indirect infringement, and validity of the only asserted claim, claim 18.” Id. Regarding the remaining two patents asserted by Power, U.S. Patent Nos. 7,110,270 and 7,834,605, the jury found that the patent’s claims were valid, but not infringed. Id. Regarding the patents asserted by Fairchild, the jury found that Power infringed U.S. Patent No. 7,259,972 under the doctrine of equivalents, that Power did not infringe U.S. Patent No. 7,352,595, and that both patents were valid. Id. (See the verdict form here).
The parties filed various motions for judgment as a matter of law as to invalidity and non-infringement, as well as motions for a new trial. The Court denied all but one post-trial motion. In that motion, Power moved for judgment as a matter of law that Fairchild directly infringed and induced infringement of its ‘605 patent, or for a new trial. Id. at 13. Judge Stark granted Power's JMOL motion as to direct infringement because “Fairchild admitted that it did ‘not present evidence of a defense with regard to direct infringement.’ In the absence of such evidence, no reasonable jury could have returned a verdict on this issue in Fairchild’s favor.” Id. (internal citation omitted). Judge Stark denied, however, Power’s motion regarding the inducement verdict, which Power argued was “the result of Fairchild’s improper trial tactics[,]” because the Court’s “curative instruction was sufficient to eliminate unfair prejudice.” Id. at 14.