Carnegie Mellon Univ. v. Marvell Tech. Grp.,Ltd., No. 14-1492 (Fed. Cir. 2015)Annotate this Case
Carnegie Mellon University sued Marvell for infringing two patents related to hard-disk drives. A jury found for CMU on infringement and validity, and awarded roughly $1.17 billion as a reasonable royalty for the infringing acts, using a rate of 50 cents for each of certain semiconductor chips sold by Marvell for use in hard-disk drives. The district court used that rate to extend the award to the date of judgment, awarded a 23-percent enhancement of the past-damages award based on Marvell’s willfulness (found by the jury and the court), and entered a judgment of $1.54 billion for past infringement and a continuing royalty at 50 cents per Marvell-sold chip. The Federal Circuit affirmed as to infringement and validity and rejection of Marvell’s laches defense to pre-suit damages, but reversed the grant of enhanced damages under the governing willfulness standard, which does not require that Marvell have had a reasonable defense in mind when it committed its past infringement. The royalty properly embraces Marvell-sold chips that, though made and delivered abroad, were imported into the U.S. A new trial is required as to Marvell chips made and delivered abroad but never imported into the U.S.
The court issued a subsequent related opinion or order on August 6, 2015.