Background
TQ Delta, LLC sued CommScope Holding Company, Inc. alleging infringement of two patents related to digital subscriber line technology, specifically the ‘008 and ‘835 patents. TQ Delta argued that because the patents were standard-essential to the ITU’s VDSL2 standard, CommScope’s products necessarily infringed. The jury found that one claim of the ‘008 patent was not infringed and one claim of the ‘835 patent was invalid, while awarding damages for other patents. TQ Delta appealed the denial of its motion for judgment as a matter of law on the infringement and invalidity findings.
The court’s reasoning
The court affirmed the district court’s decision, holding that TQ Delta failed to demonstrate that the district court erred in denying its motion for judgment as a matter of law. The court found that CommScope properly contested the standard essentiality and infringement at trial, and no stipulation existed that would foreclose the jury’s finding of non-infringement. Furthermore, the court determined that the evidence presented did not compel a finding that the VDSL2 standard met the specific claim limitations regarding phase shift computation for every carrier signal.
What it means going forward
The decision reinforces that standard essentiality does not equate to infringement and upholds jury findings where evidence is disputed regarding technical claim construction.
Source opinion
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