CAFC addresses multiple issues in Mentor Graphics vs. Eve-USA

The Mentor v. Eve-USA decision by the CAFC encompassed many issues:


We hold there was substantial evidence to support the
jury’s infringement verdict regarding the ’376 patent and
affirm the district court’s denial of judgment as a matter
of law. We affirm the damages award. We affirm the
summary judgment that assignor estoppel bars Synopsys
from challenging the validity of the ’376 patent. We
reverse the summary judgment that Synopsys’ ’109 patent
is indefinite. We affirm the summary judgment that
Synopsys’ ’526 patent lacks patent-eligible subject matter.
We vacate the motion in limine precluding Mentor from
presenting evidence of willful infringement. We reverse
the summary judgment that Mentor’s ’882 patent lacks
written description support. Finally, we reverse the
summary judgment that Mentor’s infringement allegations
regarding the ’531 and ’176 patents are barred by
claim preclusion.




Of the one issue about the motion in limine:


The district court granted a motion in limine precluding
Mentor from presenting evidence of willful infringement
of the ’376 patent. J.A. 40,545–47. We reverse.

We review evidentiary rulings under Ninth Circuit
law, which reviews for abuse of discretion. Advance
Cardiovascular Sys. v. Medtronic, Inc., 265 F.3d 1294,
1308 (Fed. Cir. 2001).

(...)

The [distict] court held that Mentor was precluded from presenting evidence
of willfulness because it relied exclusively on post-suit
willfulness conduct, and it had not first sought a preliminary
injunction. It stated, “I think Synopsys is right
about what we will call the Seagate rule, which is if you
don’t seek an injunction, you can’t seek willful infringement
for post-filing conduct.” J.A. 40,547; see In re
Seagate Tech., LLC, 497 F.3d 1360, 1374 (Fed. Cir. 2007)
(“[W]hen an accused infringer’s post-filing conduct is
reckless, a patentee can move for a preliminary injunction,
which generally provides an adequate remedy for
combating post-filing willful infringement.” (citations
omitted)). On route to this conclusion, the district court
made two errors. First, it erred in determining that the
alleged conduct was post-suit conduct because it erred in
determining the filing date of the relevant suit. Second, it
erred in concluding that Synopsys could not present
evidence of post-filing willful infringement because Synopsys
did not seek a preliminary injunction.

(...)
We hold that the district court abused its discretion in
precluding Mentor from presenting evidence of willful
infringement.