Chamberlain Group v. Techtronic Industries was decided on August 21, 2019 on appeal from the Northern District of Illinois. After the jury found plaintiff Chamberlain’s patents infringed and not invalid, the district court the district court granted an injunction, enhanced damages and attorney fees. The district court denied defendant Techtronic’s motion for JMOL of invalidity under §101 as to one patent. Techtronic appealed.
The Federal Circuit affirmed the jury verdict of no anticipation as to one patent, reversed the district court’s JMOL judgment under §101 as to the other patent, vacated the district court’s injunction and its awards of enhanced damages and attorney fees, and remanded.
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Because the Federal Circuit concluded that the asserted claims of one patent are invalid under §101 but affirmed the jury’s verdict with respect to the other patent, the Federal Circuit vacated the district court’s enhanced damages and attorney fees award and remand for the court to reconsider whether the award is warranted with respect to only the upheld patent.