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Ericsson, Inc. v. D-Link Systems, Inc.
United States Court of Appeals for the Federal Circuit
773 F.3d 1201 (Fed. Cir. 2014)
Ericsson, Inc. (plaintiff) brought suit against D-Link Systems, Inc. (defendant), alleging infringement of multiple standard-essential patents. Ericsson had promised to offer licenses for all of the relevant patents at a reasonable and non-discriminatory rate. The parties agreed that this commitment was binding on Ericsson. At trial, the jury found that D-Link did infringe on the patents and assigned roughly $10 million in damages—approximately 15 cents per infringing device. After post-trial motions, the trial court upheld the jury's infringement and validity findings and refused to grant a new trial based on allegedly deficient jury instructions regarding Ericsson's reasonable and non-discriminatory licensing obligations. D-Link appealed, arguing that the jury should have been instructed on the concepts of patent hold-up and royalty stacking, because the jury should know the problems that may arise if royalty rates are set too high. The appeal was brought before the Federal Circuit.
Rule of Law
Holding and Reasoning (O’Malley, J.)
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