Case Explained: OLLNOVA TECHNOLOGIES LTD v. ECOBEE TECHNOLOGIES ULC

Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-06-04

The federal-circuit vacated the infringement and damages judgments against ecobee Technologies ULC and remanded the case for a new trial on infringement and damages. The court held that the district court abused its discretion by submitting a single, combined jury question asking whether ecobee infringed “ANY” of the four asserted patents, rather than separate questions for each patent. Relying on *Optis Cellular Technology, LLC v. Apple Inc.*, the court found this format created an unacceptable risk of a non-unanimous verdict, as jurors could agree that infringement occurred without agreeing on which specific patent was infringed, violating the Seventh Amendment right to a unanimous jury verdict on each legal claim. Additionally, regarding the ‘495 patent’s validity under 35 U.S.C. § 101, the court vacated and remanded for further proceedings under *Alice* step two. The court determined that the district court’s jury instructions and verdict form were erroneous because they failed to identify the abstract idea found at step one (“controlling generic components using information from two separate sources”) or instruct the jury that the abstract idea itself could not supply the inventive concept. Without this instruction, the jury was permitted to treat the abstract idea as the inventive concept, rendering the error non-harmless. The court affirmed the district court’s determinations that the asserted claims of the ‘887 and ‘371 patents are not directed to an abstract idea under 35 U.S.C. § 101 at *Alice* step one, as they recite specific technological solutions to technical problems in building automation systems, such as reducing bandwidth usage and mitigating communication failures. The court also affirmed the denial of ecobee’s motion for judgment as a matter of law regarding non-infringement of the ‘371 patent, finding substantial evidence that the accused products met the claim limitations. Because the infringement and damages judgments were vacated, the court did not reach ecobee’s arguments regarding *Daubert* motions on damages or Ollnova’s argument concerning prejudgment interest under 35 U.S.C. § 286.

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