Yazdianpour v. Safeblood Techs., Inc., No. 13-3586 (8th Cir. 2015)
Annotate this CaseLicensees entered into a licensing agreement with Safeblood Tech for the exclusive rights to market patented technology overseas. After learning that they could not register the patents in other countries, Licensees sued Safeblood for breach of contract and sued Safeblood, its officers, and patent inventor for fraud, constructive fraud, and violations of the Arkansas Deceptive Trade Practices Act (ADTPA), Ark. Code 4-88-101 to -115. The district court dismissed the fraud claims at summary judgment. The remaining claims proceeded to trial and a jury found for Licensees, awarding them $786,000 in contract damages and no damages for violations of the ADTPA. The district court awarded Licensees $144,150.40 in prejudgment interest. The Eighth Circuit reversed as to the common-law fraud claim and the award of prejudgment interest, but otherwise affirmed. Licensees produced sufficient evidence that the inventor made a false statement of fact; the district court did not abuse its discretion when it gave the jury a diminution-in-product-value instruction; and Licensees waived their inconsistent-verdict argument.
Court Description: Civil case - Fraud. With respect to plaintiffs' fraud claim, the district court erred in granting defendants' motion for summary judgment as there was a disputed issue of material fact as to whether plaintiffs justifiably relied on statements made by defendants as to whether defendants owned the rights to the patent in question outside the United States; under Arkansas law, the district court did not err in instructing the jury that plaintiffs could not recover under the Arkansas Deceptive Trade Practices Act if the only injury they suffered was diminution in the value of the product; plaintiffs waived their inconsistent verdict argument by failing to raise the objection before the jury was discharged; with respect to defendants' cross-appeal, their claim that the verdict was against the weight of the evidence could not be considered because they failed to renew their motions for judgment as a matter of law under Rule 50(b); under Arkansas law, the district court abused its discretion when it awarded plaintiffs prejudgment interest on their breach-of-contract claim; remanded for trial of plaintiffs' fraud claim.
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