Background
Ollnova Technologies sued ecobee for patent infringement in the Eastern District of Texas, asserting four patents related to wireless communications in building automation systems. A jury found ecobee infringed at least one patent, awarded Ollnova eleven point five million dollars in damages, and found one patent’s claims were not well-understood, routine, and conventional. ecobee appealed, challenging the verdict form, jury instructions, and patent eligibility determinations.
The court’s reasoning
The Federal Circuit vacated the infringement and damages judgments because the district court used a single verdict question covering all asserted patents, creating an unacceptable risk of a non-unanimous general verdict. The court also vacated and remanded the eligibility analysis for the four nine five patent because the jury instructions failed to identify the abstract idea, preventing the jury from properly determining if the claims contained an inventive concept beyond that idea. The court affirmed the district court’s determinations that the eight eight seven and three seven one patents are not directed to an abstract idea.
We vacate the infringement and damages judgments and remand for proceedings consistent with this opinion, including a new trial on infringement and damages.
OLLNOVA TECHNOLOGIES LTD. v. ECOBEE TECHNOLOGIES ULC, 2025-1045 (Fed. Cir. June 4, 2026)
What it means going forward
The case returns to the district court for a new trial on infringement and damages with a revised verdict form that separates questions for each patent. The district court must also provide proper jury instructions on patent eligibility that identify the abstract idea for the four nine five patent.