Koninkiljke Philips Electronics N.V. v. Zoll Medical Corp. (10-cv-11041).

Judge Gorton granted the plaintiffs’ motion in limine to exclude Zoll’s expert from testifying about the invalidity of claims of two patents in defense of charges of willful infringement of a third patent. His reasoning was two-fold; first, the invalidity of claims from a different patent is not probative of whether infringement of a third patent was willful, and second, invalidity was first found on appeal, well after the infringement occurred, and thus the invalidity of the claims of the other patents could not serve as evidence of the state of mind of the infringer under the Supreme Court’s Halo decision of 2016.

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