Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial and Appeal Board.
Wonderland Switzerland AG v. Evenflo Co., Inc.
Nos. 2023-2043, -2233, -2326 (Fed. Cir. (D. Del.) Dec. 17, 2025). Opinion by Moore, joined by Prost. Opinion concurring in part and dissenting in part by Reyna.
Wonderland sued Evenflo for infringement of two patents relating to children’s car seats. At trial, the jury returned a verdict finding that Evenflo’s convertible car seats infringed both patents and that Evenflo’s infringement of one patent was not willful. After trial, the district court granted Wonderland’s motion for a permanent injunction and denied the parties’ cross-motions for judgment as a matter of law and for a new trial. Notably, although Wonderland moved for a permanent injunction as to only one of the patents, the court permanently enjoined Evenflo’s activities relating to both patents.
Evenflo appealed the court’s final judgment and permanent injunction order, and Wonderland cross-appealed the denial of a new trial on willful infringement.
Evenflo’s appeal focused on three main areas: the jury’s findings of infringement by Evenflo’s “4-in-1 seats,” several claim construction rulings, and the district court’s permanent injunction.
First, Evenflo argued that the seat backs of its accused 4-in-1 seats do not include the required “locking mechanism” and that no reasonable jury could have found otherwise. The Federal Circuit agreed, ruling that “there is no substantial evidence the 4-in-1 seats include any such feature.”
Next, Evenflo argued that the district court committed several claim construction errors, including failing to resolve a claim construction dispute, failing to construe a term, and incorrectly construing the term “connected to.” The Federal Circuit disagreed with each of the challenges. For example, as to the “connected to” term, the Federal Circuit upheld the district court’s construction that the term refers “not only to separate pieces that are later connected, but also to different parts or features that are discrete yet formed out of a continuous base material.” The Federal Circuit rejected Evenflo’s arguments that components “connected to” one another are presumed to be physically distinct: “We … reject the notion that our precedent establishes a presumption or per se rule that controls the construction of ‘connected to.’”
Lastly, Evenflo challenged the district court’s decision to permanently enjoin activities relating to both asserted patents. For one of the patents, Wonderland had expressly declined to request an injunction. The Federal Circuit thus agreed with Evenflo, ruling it was “an abuse of discretion to grant such an extraordinary remedy when a party did not request it.” As to the second patent, the Federal Circuit again agreed with Evenflo that the permanent injunction was unwarranted. The district court abused its discretion in granting the injunction because the court “relied solely on speculative and conclusory evidence” of irreparable harm or injury.
In Wonderland’s cross-appeal, Wonderland argued that the district court abused its discretion by denying a new trial on willful infringement. Wonderland insisted that the court erroneously excluded trial evidence of Evenflo’s subjective intent to infringe. The district court had excluded the evidence under Federal Rule of Evidence 403 because it determined the probative value was substantially outweighed by a danger of unfair prejudice and confusion. The Federal Circuit disagreed with the district court and thus reversed the denial of a new trial on willful infringement. The Federal Circuit held that the district court abused its discretion because the evidence had “high probative value for the issue of willfulness that far outweighs the limited concerns identified by the district court.”
Accordingly, the Federal Circuit affirmed-in-part, reversed-in-part, and vacated-in-part the district court’s judgment and remanded for further proceedings.
Judge Reyna concurred-in-part but dissented as to the new trial on willful infringement. In his view, the district court did not abuse its discretion in excluding the evidence of Evenflo’s subjective intent to infringe. Judge Reyna thus would have affirmed the denial of a new trial on willful infringement because, in his view, the district court’s decision to exclude the evidence “was neither arbitrary nor irrational but instead reflected a careful and comprehensive balancing of the weight of the evidence’s probative value against the risk of prejudice and jury confusion.”