Synqor, Inc. v. Artesyn, Inc.

PATENTS; INDUCED INFRINGEMENT: Datasheets and other markings on patented material showed actual knowledge required to prove induced infringement.

Opinion (Radar): Synqor, Inc. (“SI”) brought suit against Artesyn, Inc. (“AI”) for manufacturing and selling power converters overseas with the knowledge that they would be installed in products intended to be imported to the United States, thus inducing infringement. In district court, a jury found infringement. AI moved for a JMOL, arguing for patent invalidity, and against induced infringement and enhanced damages. The district court denied AI’s motion for a JMOL. AI appealed, arguing that the jury instructions were inadequate, and permitted a finding of inducement without actual knowledge. The Court found that the knowledge element required to prove induced infringement was present, based on SI datasheets and SI marked converters. As a result, the Court determined that such evidence was sufficient for a reasonable juror to determine AI had actual knowledge of inducement. In determining patent invalidity, the Court contemplated different components and design involved in the input and output of the converter. Skepticism of SI’s engineers, industry recognition, skepticism of other experts, and unexpected results all indicated nonobviousness. The court found the enhanced damages appropriate, because AI acted egregiously in increasing sales in the face of an infringement verdict. Thus, the Court AFFIRMED the judgment.