Dennis Crouch's comprehensive write-up on the case, Columbia Sportsware v. Seirus Innovative Accessories, is available here. According to the post, the jury awarded the plaintiff $3,018,174, and while the jury instructions asked the jury to "identify the 'article of manufacture’ to which the infringed design has been applied," based on consideration of several factors, "the jury was not asked to actually define the article of manufacture," and "the $3 million figure appears to be Seirus’s profits on all of its infringing sales" (emphasis mine).
As readers of this blog are probably aware, I'm not a big fan of disgorgement generally, especially when (as apparently was the case here) it results in an award of all of the profit earned on a multi-feature product. Beyond that, in my view it would make sense if judges more frequently used special verdicts or general verdicts with special interrogatories, as permitted under Federal Rule of Civil Procedure 49, to better test whether a jury's determination is supported by the evidence. Here, the judge might have required the jury to define the relevant article of manufacture.
Or maybe we could figure out a way to avoid having juries determine these questions altogether . . . could the recovery of the infringer's profits be viewed as an equitable remedy for which there is no constitutional right to a jury trial?