From our private database of 33,800+ case briefs...
Delta-X Corp. v. Baker Hughes Production Tools Inc.
United States Court of Appeals for the Federal Circuit
984 F.2d 410, 25 U.S.P.Q.2d 1447 (1993)
Delta-X Corporation (plaintiff) was assigned United States Patent No. 4,286,925 (the 925 patent), which disclosed a means for turning off power to a well if the oil pump was experiencing fluid pound. Delta-X sued Baker Hughes Production Tools, Inc., and Baker CAC (collectively, Baker) (defendants) for infringement in federal court, arguing that Baker’s rod pump controllers infringed the 925 patent. Delta-X and Baker disagreed about the meaning of the term electrical comparator in the 925 patent. Baker requested that the district court instruct the trial jury that an electrical comparator was not synonymous with a computer. The district court declined to issue Baker’s requested instruction and instead chose to give the jury the task of claim interpretation. During jury instructions, the district court told the jury to compare the accused Baker device with the properly interpreted claims. Some parts of the jury instructions implied that the court would interpret the claims instead of the jury. However, the instructions also included multiple direct references to the jury’s responsibility to interpret the claims and then apply the law to their interpretations. Baker objected to the issued jury instructions at the end of trial but did not move for a directed verdict. The jury found that Baker was liable for willful infringement of the 925 patent under the doctrine of equivalents. Delta-X requested enhanced damages, attorney’s fees, and costs based on the willfulness finding. Baker requested that the district court deny Delta-X’s motion and moved for judgment notwithstanding the verdict (JNOV) on the jury’s willfulness finding. The district court denied Delta-X’s request for enhanced damages, granted Baker’s motion for JNOV, and set aside the jury’s finding of willfulness. The district court also found independently of the JNOV that Delta-X had failed to make a sufficient case for enhanced damages. Delta-X appealed, and Baker cross-appealed.
Rule of Law
Holding and Reasoning (Rader, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 604,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 604,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 33,800 briefs, keyed to 984 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.