Streamline Production Systems, Inc. v. Streamline Manufacturing, Inc., No. 16-20046 (5th Cir. 2017)Annotate this Case
Streamline Production filed a trademark infringement suit against Streamline Manufacturing, seeking damages under the Lanham Act, 15 U.S.C. 1051 et seq., and Texas common law. The parties stipulated to an injunction and a jury returned a verdict finding that Streamline Manufacturing infringed on Streamline Production's valid trademark in its name and awarded damages for lost royalties, unjust enrichment, and exemplary damages. The district court denied Streamline Manufacturing's motion for judgment as a matter of law (JMOL), as well as its renewed JMOL, or in the alternative, for a new trial. The court concluded that there was insufficient evidence to support the royalty award where, given the limited nature of the expert testimony on royalty damages and the other evidence presented at trial on the nature of Streamline Manufacturing's infringement and customers, the royalty award does not bear a rational relationship to the infringing use; the unjust enrichment award was not supported by sufficient evidence; and, because the court vacated the royalty and unjust enrichment awards for insufficient evidence, the court also vacated the exemplary damages award. The court otherwise affirmed the judgment.