Last week, Judge Robinson issued a lengthy memorandum opinion in Robert Bosch, LLC v. Pylon Man. Corp., C.A. No. 08-542-SLR (D. Del. Nov. 3, 2010), granting in part a motion for judgment as a matter of law and overturning jury verdicts on the issue of invalidity of several patent claims (and denying other motions including a motion for a permanent injunction).
The jury’s invalidity findings were reversed for lack of substantial evidence. Judge Robinson had previously granted motions in limine which, “viewed in light of the options available on the jury’s verdict sheet, precluded a finding of obviousness based on any single prior art reference or any combination of prior art references that did not include the ‘564 patent.” The Jury found the four claims invalid based on references other than the ‘564 patent. Judge Robinson held that, because Defendants had been precluded from offering evidence on these references, the jury’s verdict could not be supported by substantial evidence.
Judge Robinson also denied Plaintiff’s motion for a permanent injunction, under the eBay standard, because of “[Plaintiff]’s failure to define a relevant market, the existence of additional competitors and the non-core nature of [Plaintiff’s sale of the relevant products] in relation to its business as a whole.”