Apple Wins New Trial in $300 Million LTE Patent Dispute with Optis Over Jury Verdict Form and Damages Evidence

In a significant decision for patent litigation, the Federal Circuit has vacated a $300 million damages award against Apple Inc. in its ongoing dispute with Optis Cellular Technology, LLC and related entities over five standard-essential patents (SEPs) covering LTE technology. The court found that the Eastern District of Texas erred by using a single, combined infringement question for all five patents on the jury verdict form, depriving Apple of its right to a unanimous jury verdict on each individual patent claim.

The case involved five patents U.S. Patent Nos. 9,001,774; 8,019,332; 8,385,284; 8,102,833; and 8,411,557, all of which were declared essential to the LTE standard and subject to fair, reasonable, and non-discriminatory (FRAND) licensing commitments. After an initial jury awarded Optis over $500 million, a new trial on damages was ordered due to the exclusion of evidence about Optis’s FRAND obligations. The second jury awarded $300 million, but Apple appealed, challenging the verdict form, claim construction, patent eligibility, and the admission of certain damages evidence.

The Federal Circuit agreed with Apple that the single infringement question on the verdict form was improper, as it allowed the jury to find infringement even if jurors disagreed on which patent was infringed. The court also found that the district court erred by admitting evidence of a large Apple-Qualcomm settlement agreement, which was not closely related to the patents at issue and risked unfairly prejudicing the jury. Additionally, the court ruled that two claims of the ’332 patent were directed to an unpatentable abstract idea (a mathematical formula), and that a claim in the ’557 patent invoked means-plus-function claiming, requiring further analysis on remand.

As a result, both the infringement and damages judgments were vacated, and the case was sent back for a new trial. The decision underscores the importance of clear jury instructions and careful handling of damages evidence in complex patent cases, especially those involving standard-essential patents and FRAND commitments.

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