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Exmark Manufacturing Co. v. Briggs & Stratton Corp.

2019 WL 1596822 (2019)

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Exmark Manufacturing Co. v. Briggs & Stratton Corp.

United States District Court for the District of Nebraska
2019 WL 1596822 (2019)

Facts

Exmark Manufacturing Company (Exmark) (plaintiff) won a patent-infringement lawsuit against Briggs & Stratton Corporation (defendant). The trial court found for Exmark and ordered Briggs & Stratton to pay prejudgment interest on royalty payments it owed to Exmark. While that prejudgment interest was accruing, the United States Treasury rate (the Treasury rate) was almost zero percent, but borrower interest rates, including the prime rate, were much higher. Briggs argued that the court should apply the Treasury rate to all of Exmark’s damages. Exmark argued that the Treasury rate should be applied for the period before the lawsuit was filed, and the prime rate should be applied for the period between filing and the issuance of the judgment. In support of its argument, Exmark presented evidence that its cost of borrowing at all times relevant to the case had been higher than both the treasury rate and the prime rate. The district court considered which interest rate to apply.

Rule of Law

Issue

Holding and Reasoning (Baitailon, J.)

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