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Monday, April 7, 2025

OxFirst Webinar on HMD Global v. VoiceAge

OxFirst will be presenting a free webinar on Wednesday, April 9, at 15:00 BST (9:00 a.m. U.S. Central Time) on the OLG Munich’s decision in HMD Global v. VoiceAge (see my post below from this past Saturday).  The speaker will be Dr. Oliver Schoen, Presiding Judge of the 7th Civil Chamber of the Munich I Regional Court.   Here is a link to register, and here is the description:

 

In this talk, Dr Oliver Schoen will talk about the recent decision in Voice Age vs HMD.

 

Munich continues to be centre stage of FRAND disputes in Europe and internationally. In this webinar, Judge Dr Oliver Schoen will be addressing key issues of standard essential patent disputes in the immediate aftermath of the VoiceAge vs HMD decision. He will look at the key developments the judgment touches upon in the FRAND space and also look at the Amicus Brief of the European Commission.

 

Does the judgment offer new insights on some key FRAND matters, such as what constitutes as unwilling licensee, the future of injunctions and FRAND rate setting in a Munich context?

Saturday, April 5, 2025

OLG Munich’s Written Decision in VoiceAge v. HMD Is Now Out

Here it is, the Judgment of March 20, 2025, Case 6 U 3824/22. in the original German, courtesy of Matthias Leistner.  Dr. Leistner, who holds the GRUR Chair at Ludwig-Maximilians-Üniversität in Munich, will be giving a lecture at the University of Minnesota next Tuesday on FRAND developments in Europe, which I am very much looking forward to.  He also shared with me a copy of his new paper, The Current German SEP/FRAND Practice--An Overview with a Focus on the Sprachsignalkodierer Decision of the Munich Higher Regional Court and Some Thoughts on Possible Ways Forward, GRUR Patent 2025, which I have may more to say about next week or soon thereafter.

Anyway, the OLG Munich's FRAND discussion begins at p.22 (Part VI) of the decision.  As previously reported, based on last month's hearing, the court rejects the European Commission’s approach, as set forth in the Commission's amicus brief, that the Huawei v. ZTE steps must be followed in strict sequence (see pp. 24-25).  The court reasons that if the SEP owner’s first offer is within the FRAND range, there is no need to further consider the competition-law defense, even though further negotiation could result in a lower agreed-upon rate.  Therefore, the court infers, it is only if the offer isn’t FRAND-compliant that one needs to consider the implementer’s counteroffer.  Consistent with other German cases, the court would consider only whether the initial offer was obviously not-FRAND; and the same would be true for the implementer’s counteroffer.  Both parties are obligated only to submit an offer or counteroffer that is, in their good faith, subjective estimation, within the FRAND range.  (pp. 29-31).  If the counteroffer is rejected, the implementer should provide security in the amount of the SEP owner’s last offer.  That last offer can be for a global portfolio license, in which case the security cannot be just for the patent in suit or for Germany (p.34). 

One thing that occurs to me as I read this is that there is something of a range of opinion, globally, concerning what sort of security or interim license the implementer might have to pay pending further proceedings.  Some of the Indian FRAND cases have required the defendant to deposit an amount corresponding to the SEP owner’s offer, whereas the recent U.K. decisions on interim licenses have stated that a reasonable interim license would be midway between the SEP owner’s and the implementer’s last offer/counteroffer.  By contrast, the UPC Munich Division in Huawei v. Netgear stated in dictum (p.137) that the security must be at least in the amount of the counteroffer, while noting that the OLG Munich during the proceedings in HMD in October 2024 had indicated it should be in the amount of SEP owner's offer, but that the matter could be left open since the defendant hadn't provided either.  Dr. Leistner states in his new paper that he believes the middle-way approach would be preferable. 

Wednesday, April 2, 2025

Federal Circuit Vacates Judgment Including Lost Profits on Convoyed Sales

On Monday I blogged about the Federal Circuit’s nonprecedential opinion last week in Roland v. InMusic, which discussed (among other things) the “inexorable flow” exception to the U.S. rule that a patent owner can recover lost profits only for its own lost profits, and not for those of a subsidiary or other affiliated company.  Last week’s other Federal Circuit decision on damages, Wash World, Inc. v. Belanger Inc., is a precedential opinion authored by Judge Stark, joined by Judges Lourie and Prost.  Much of the opinion addresses the question of whether the defendant forfeited certain arguments relating to claim construction by not raising them in a timely fashion before the district court.  (The Federal Circuit’s answer:  yes as to two issues of claim construction, no as to the third but it doesn’t matter because the district court’s construction was correct.)  A similar question comes up in connection with the damages award, but the court concludes that there was no forfeiture.  The damages issue on appeal is therefore whether there was sufficient evidence for the jury award of $9.6 million in lost profits, given that about $2.6 million of it apparently related to “convoyed” sales.  The Federal Circuit concludes that there was not, and therefore remands with instructions to remit the $2.6 million.

Convoyed sales are sales of goods or services that are complementary to the sale of the patented article.  They may include things such as spare parts or other nonpatented subject matter that may typically be sold along with the patented subject matter.  In Rite-Hite Co. v. Kelley Corp., 56 F.3d 1538, 1550 (Fed. Cir. 1995) (en banc), the Federal Circuit announced the following standard for deciding when the patent owner may recover lost profits on sales of these convoyed goods:

. . . when recovery is sought on sales of unpatented components sold with patented components, to the effect that the unpatented components must function together with the patented component in some manner so as to produce a desired end product or result. All the components together must be analogous to components of a single assembly or be parts of a complete machine, or they must constitute a functional unit. Our precedent has not extended liability to include items that have essentially no functional relationship to the patented invention and that may have been sold with an infringing device only as a matter of convenience or business advantage.

As I discuss in my forthcoming book Remedies in Intellectual Property Law, the requirement that the convoyed goods “function together with the patented article,” and not merely be sold along with the infringing product as a matter of convenience, differs from the rule followed in the U.K., France, Japan, and Germany, all of which apply a simple but-for principle, albeit subject to limitations on damages for harms that are too remotely caused by the infringement.  In our article Rethinking Patent Damages, 10 Tex. Intell. Prop. L.J. 1, 89 (2001), Roger Blair and I argued that the Federal Circuit's rule might be justified as a sort of bright-line proximate causation rule.  In Patent Remedies for Complex Products:  Toward a Global Consensus (C. Bradford Biddle et al. eds., 2019), on the other hand, my coauthors and I, in the chapter titled Lost Profits and Disgorgement, recommended that courts should award lost profits on sales of convoyed goods “provided that the patentee can demonstrate both (1) “but for” causation and (2) proximate causation, which is established by demonstrating that sales of the unpatented component, part, or good was ‘reasonably foreseeable by an infringing competitor in the relevant market,’” and I am inclined to think that that is the better view.  The meaning of “function together with the patented component” is itself not always clear, as the Wash World case shows.  There, the relevant claim was for a “spray-type car wash system” comprising three elements: a carriage, a spray arm mounted from the carriage, and a lighting system distributed along the arm.  The convoyed goods were unpatented dryers (see opinion p.24).  As Dennis Crouch points out, however, in his post yesterday about the case, although “according to the court, the patentee did not present evidence of how the components functionally interacted or depended on each other,” perhaps the patentee could have “presented specific evidence showing that the dryers were functional aspects of a carwash system–part of a single unit that is ordinarily sold together”--or drafted its claims more broadly to cover the entire car wash system, not just the novel feature.  If so, the Federal Circuit’s rule seems kind of arbitrary.  Moreover, while a full compensation rule may or may not be necessary to provide the optimal incentive to invent (or optimal deterrence of infringement), it is a simple rule to understand; and traditional proximate causation analysis arguably is sufficient to ensure that losses that are too remote, unforeseeable, indirect, etc. would be excluded.