In a recent memorandum order, Judge Leonard P. Stark entered a preliminary injunction in a suit involving GPS modules supplied to the Ford Motor Company. M/A-COM Technology Solutions Holdings, Inc. v. Laird Techs., Inc., C.A. No. 14-181-LPS (June 13, 2014) (public version June 16, 2014). The plaintiff had, for several years, been Ford’s sole supplier of GPS modules for installation in its automobiles, but the defendant won a contract with Ford to supply GPS modules beginning with a shipment in mid-July 2014. The plaintiff responded by filing suit and alleging that the defendant’s GPS modules infringed the plaintiff’s patent.
The Court allowed limited discovery, following by full briefing, oral argument, witness testimony, and supplemental briefing, and ultimately found that a preliminary injunction was justified. The Court found that the plaintiff would likely prevail at proving infringement, and specifically rejected the defendant’s proposed constructions of certain terms that would limit their scope and exclude a disclosed embodiment in order to avoid infringement. The Court also found that the plaintiff would likely prevail at showing that the defendant was not given rights to infringe through a license agreement between the plaintiff and Ford, and that the defendant failed to raise a substantial question concerning invalidity based on anticipation or obviousness.
The Court next considered whether the plaintiff demonstrated that it would be irreparably harmed absent a preliminary injunction. The Court found that the plaintiff’s relationship with Ford was threatened with damage that could not be fully remedied through money damages in the form of price erosion and damage to its relationship with Ford. And although the Court found that a preliminary injunction would significantly harm the defendant, that harm was outweighed by the harm the plaintiff would experience absent an injunction.
Lastly, the Court found that the balance of competing public interests weighed in favor of an injunction. In this analysis the Court considered the interest in protecting patent rights, and also the interest in encouraging patent litigation to proceed at a reasonable pace—with parties not rushing to Court when a concrete dispute may never ripen (the defendant accused the plaintiff of unduly delaying the litigation), outweighed the “disruptive effect” the injunction would have no Ford, especially since Ford “has not appeared and nothing in the record would support a finding that Ford (and, through Ford, the public) will be harmed as a result of” an injunction.