United States District Court, D. Delaware
GREGORY M. SLEET, District Judge.
In this patent infringement action, plaintiff Avid Technology, Inc. ("Avid"). alleges that products manufactured by defendant Harmonic Inc. ("Harmonic") infringe the asserted claims of the patents-in-suit. (D.I. 1.) The court held a nine-day jury trial in this matter on January 23 through February 4, 2014. (D.I. 169-177.) At trial, both parties properly moved for judgment as a matter of law ("JMOL") on a number of grounds pursuant to Rule 50(a) of the Federal Rules of Civil Procedure. (D.I. 151, 152.)
On February 4, 2014, the jury returned a unanimous verdict in favor of Harmonic on the issue of infringement with respect to all asserted claims. (D.I. 158 at 2-4.) The jury further found in favor of Avid that none of the asserted claims were invalid due to anticipation or obviousness. ( Id. at 5-6.) The court entered judgment on the verdict on April 15, 2014. (D.I. 164.) Presently before the court is Avid's renewed JMOL motion or, alternatively, motion for a new trial, pursuant to Rules 50(b) and 59 of the Federal Rules of Civil Procedure. (D.I. 168.) Having considered the substantial evidence in the record, the parties' post-trial submissions, and the applicable law, the court will deny Avid's motion. The court's reasoning follows.
II. BACKGROUND OF THE TECHNOLOGY
The patents-in-suit relate to shared digital storage systems. These systems are used to allow multiple users to work collaboratively on large data projects, e.g., movie editing. Avid asserts that Harmonic's MediaGrid product infringes the '808 and '309 Patents. There are two remaining disputes central to the parties' infringement positions: (1) whether the MediaGrid product employs a "central controller" to access stored data, such that it does not practice the "independent storage units" element of the asserted claims; and (2) whether the MediaGrid product stores data "in files."
III. STANDARD OF REVIEW
Avid's motion asserts that is entitled to judgment as a matter of law pursuant to Rule 50 of the Federal Rules of Civil Procedure or, alternatively, that it is entitled to a new trial pursuant to Rule 59.
A. Renewed JMOL Motion
To prevail on a renewed motion for judgment as a matter of law following a jury trial and verdict, the moving party must show that the jury's findings, presumed or express, are not supported by substantial evidence or, if they were, that the legal conclusion(s) implied [by] the jury's verdict cannot in law be supported by those findings.'" Pannu v. bolab Corp., 155 F.3d 1344, 1348 (Fed. Cir. 1998) (quoting Perkin-Elmer Corp. v. Computervision Corp., 732 F.2d 888, 893 (Fed. Cir. 1984)). "Substantial evidence" is defined as "such relevant evidence from the record taken as a whole as might be accepted by a reasonable mind as adequate to support the finding under review." Perkin-Elmer Corp., 732 F.2d at 893; see also SIBIA Neuroscis., Inc. v. Cadus Pharm. Corp., 225 F.3d 1349, 1354 (Fed. Cir. 2000) ("A factual finding is supported by substantial evidence if a reasonable jury could have found in favor of the prevailing party in light of the evidence presented at trial.")
"This court draws all reasonable inferences in favor of the prevailing party without substituting its view of conflicting evidence for that of the jury." Rambus Inc. v. Infineon Techs. Ag, 318 F.3d 1081, 1086-87 (Fed. Cir. 2003). To this end, the court is not to make credibility determinations. See SIBIA Neuroscis., 225 F.3d 1349 at 1355. Only if, "after reviewing all of the evidence in a light most favorable to the prevailing party, this court is convinced that a reasonable jury could not have found in that party's favor" is the grant of JMOL proper. Id.
B. New Trial
Pursuant to Federal Rule of Civil Procedure 59, a court may grant a new trial "for any of the reasons for which a new trial has heretofore been granted in an action at law in federal court." Fed.R.Civ.P. 59(a)(1)(A).. The decision to grant or deny a new trial is within the sound discretion of the trial court. See Allied Chem. Corp. v. Daiflon, Inc., 449 U.S. 33, 36 (1980). In making this determination, the trial judge should consider the overall setting of the trial, the character of the evidence, and the complexity or simplicity of the legal principles which the jury had to apply to the facts. Lind v. Schenley Indus., Inc., 278 F.2d 79, 89 (3d Cir. 1960). Unlike the standard for determining judgment as a matter of law, the court need not view the evidence in the light most favorable to the verdict winner. Allied Chem. Corp., 449 U.S. at 36. A court should grant a new ...