Rudolph Technologies succeeds in appeal to CAFC

Rudolf Technologies did well in its appeal to the CAFC:


Rudolph Technologies, Inc. (Rudolph)
appeals from the district court’s
judgment that it infringes U.S. Patent
No. 6,118,894 (’894 patent )
. Rudolph challenges the
court’s denial of its motion for
judgment as a matter of law (JMOL )
that prosecution history estoppel
bars the application of the doctrine of
equivalents
.
Rudolph also challenges the
award of damages, the court’s determina-
tion that this was an exceptional case
under 35 U.S.C. § 285 ,
and that Rudolph failed to prove laches.
We hold that prosecution history estoppel
precludes the application of the
doctrine of equivalents and therefore
reverse the judgment of infringement
under the doctrine of equivalents.
We also reverse the
willfulness finding predicated on
that judgment and vacate the corresponding
award of enhanced damages .
1
We affirm the award of damages for
literal infringement .
We vacate the award of attorneys’
fees and costs and remand
because we find that the
court’s exceptional case analysis relied in part on the
willfulness finding
.
Finally,
we hold that the court did
not abuse its discretion in finding no laches.