STEUBEN FOODS, INC. v. SHIBUYA HOPPMANN CORPORATION , No. 23-1790 (Fed. Cir. 2025)
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Steuben Foods, Inc. (Steuben) filed a complaint in 2010 in the United States District Court for the Western District of New York, alleging that Shibuya Hoppmann Corp. infringed claims of U.S. Patent Nos. 6,209,591, 6,536,188, and 6,702,985. Shibuya Kogyo Co., Ltd. was added as a defendant in 2012, and a similar complaint was filed against HP Hood LLC. The cases were consolidated and later transferred to the District of Delaware in 2019. The district court issued a claim construction order in 2020 and denied cross-motions for summary judgment in 2021. A five-day jury trial resulted in a verdict that the asserted patents were valid and infringed, awarding Steuben $38,322,283.78 in damages.
The district court granted Shibuya’s motion for judgment as a matter of law (JMOL) of noninfringement for all asserted patents, found the invalidity arguments waived, and conditionally granted a new trial. Steuben appealed the JMOL and the conditional grant of a new trial.
The United States Court of Appeals for the Federal Circuit reviewed the case. The court reversed the JMOL of noninfringement for the ’591 and ’188 patents, finding substantial evidence supported the jury’s verdict of infringement. The court affirmed the JMOL of noninfringement for the ’985 patent, holding that the continuous addition of sterilant could not be equivalent to the claim’s requirement of intermittent addition. The court also reversed the conditional grant of a new trial on noninfringement and vacated the conditional grant of a new trial on invalidity and damages, remanding for further proceedings.
The main holdings were: reversing the JMOL of noninfringement for the ’591 and ’188 patents, affirming the JMOL of noninfringement for the ’985 patent, reversing the conditional grant of a new trial on noninfringement, and vacating the conditional grant of a new trial on invalidity and damages.
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