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Crystal Semiconductor Corp. v. TriTech Microelectronics International
United States Court of Appeals for the Federal Circuit
246 F.3d 1336 (2001)
Crystal Semiconductor Corp. (Crystal) (plaintiff) sold patented audio chips, each having analog-to-digital and digital-to-analog converters on a single chip. By 1994, the chips were used in Apple and PC computers. The PC market was competitive, including a chip sold by TriTech Microelectronics International (TriTech) (defendant). However, the Apple market was exclusive to Crystal and another competitor, working together according to Apple’s specifications. Crystal sued TriTech for infringement and requested loss of profits based on a price-erosion theory. To support its theory, Crystal offered expert testimony based on analysis comparing the sales of Crystal’s chip in the Apple market, an infringement-free environment, with its sales in the PC market in competition with TriTech’s alleged infringing product. After trial, a jury returned a verdict of over $26 million in price-erosion damages. The district court granted TriTech’s judgment as a matter of law remitting the damages, finding Crystal had not proven price erosion. Crystal appealed.
Rule of Law
Holding and Reasoning (Rader, J.)
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