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.
Willis Electric Co., Ltd. v. Polygroup Ltd. (Macao Commercial Offshore), et al.
No. 2024-2118 (Fed. Cir. (D. Minn.) Feb. 17, 2026). Opinion by Moore, joined by Stark and Oetken (sitting by designation).
Willis sued Polygroup for infringement of a patent directed to pre-lit artificial trees. A jury found the lone asserted claim infringed and not invalid, and awarded about $42.5 million in damages. After the district court denied Polygroup’s motion for judgment as a matter of law of obviousness and for a new trial on damages, Polygroup appealed.
The Federal Circuit first addressed Polygroup’s argument that the asserted claim was obvious. The court viewed its “narrow[] task” as “determining whether substantial evidence supports the jury’s presumed factual finding on motivation to combine.” The court ruled that substantial evidence supported the finding, including expert testimony that modifying the prior art would have required significant redesign.
The Federal Circuit then turned to Polygroup’s request for a new trial on damages. The sole claim at issue, claim 15, is a dependent claim that depends from a claim found to be invalid in an IPR. Polygroup thus argued that Willis’s recoverable damages are limited to the use of coaxial barrel connectors (the feature added in claim 15).
The Federal circuit disagreed, explaining that “the cited IPR determination was subject to the broadest reasonable interpretation standard for claim construction, which resulted in a construction of claim 10 different from the one the district court reached under the Phillips standard. … Thus, neither the Board nor the district court found claim 10 unpatentable under the district court’s construction. For at least this reason, the IPR determination does not preclude Willis from relying on the one-step functionality of claim 10 as part of the value attributable to the coaxial barrel connectors of claim 15.”
Polygroup also argued that Willis’s damages expert relied on inaccurate assumptions, imperfect data, and insufficiently comparable licenses. Polygroup further contended that the expert’s use of income‑based and market‑based analyses, as well as her application of the Georgia‑Pacific factors, impermissibly attributed value to unpatented aspects of the accused products.
The Federal Circuit disagreed with these arguments as well. The court emphasized the distinction between admissibility, which is governed by Rule 702, and weight and credibility, which are matters for the jury. Rule 702 requires analyzing whether an expert’s methodology is sufficiently reliable and does not require resolving disputes over the correctness of the expert’s assumptions or conclusions. Also, the Federal Circuit noted that calculating a reasonable royalty “necessarily involves an element of approximation and uncertainty,” so “mathematical certainty” is not required.
Applying those principles, the Federal Circuit held that the district court did not abuse its discretion in admitting the damages expert’s testimony. The Federal Circuit concluded that Willis’s expert employed recognized methodologies—profit‑based comparisons, analysis of comparable licenses, and consideration of the Georgia‑Pacific factors—and that Polygroup’s objections were properly presented to the jury through cross‑examination and competing evidence. The Federal Circuit therefore affirmed the district court’s denial of Polygroup’s motion for a new trial on damages.
Genuine Enabling Technology LLC v. Sony Group Corp., et al.
No. 2024-1686 (Fed. Cir. (D. Del.) Feb. 19, 2026). Opinion by Chen, joined by Dyk and Taranto.
Genuine Enabling Technology (GET) sued Sony for infringement of a patent directed to combining multiple input data streams for transmission to a computer. The key claim limitation at issue was a means-plus-function limitation—“encoding means for synchronizing” two input data streams—and the specification described FIG. 4A’s logic block 34, a logic design circuit containing a multitude of elements, as the corresponding structure for performing the synchronizing function.
In analyzing infringement, GET’s expert omitted certain elements from logic block 34, focusing on just a bit-rate clock signal and not, for example, information about a Bluetooth module, which GET had not obtained discovery on. Because the expert’s testimony that the claimed and accused structures were equivalent was unsupported by his limited analysis of solely the bit-rate clocks, the district court excluded his “ultimate conclusion.” The district court then awarded Sony summary judgment of noninfringement. GET appealed.
The Federal Circuit affirmed, explaining that “because GET and its expert failed to account for many of the elements in block 34 in their infringement analysis, we agree with the district court that GET presented a deficient infringement case as to this limitation.”
The Federal Circuit reiterated that a component‑by‑component comparison is not required to demonstrate structural equivalence. But “the patentee must still account for each element of the claimed structure in its equivalence analysis.” The Federal Circuit agreed that GET’s expert improperly focused on a single aspect of the disclosed logic block while failing to explain why the remaining elements of the logic block were insubstantial. The Federal Circuit held that the analysis of the accused Bluetooth module was conclusory, improperly collapsed the function-way-result test into a function-result test, and was inconsistent with the patent’s description of a detailed logic block rather than a “black box.”
REGENXBIO Inc., et al. v. Sarepta Therapeutics, Inc., et al.
No. 2024-1408 (Fed. Cir. (D. Del.) Feb. 20, 2026). Opinion by Stoll, joined by Dyk and Hughes.
REGENXBIO sued Sarepta for infringement of a patent directed to genetically engineered host cells and nucleic acid molecules used in gene therapy. Both parties moved for summary judgment on whether the asserted claims were eligible under 35 U.S.C. § 101. The parties agreed there were no underlying factual disputes pertaining to eligibility. The district court granted Sarepta’s motion and held the claims ineligible as directed to a natural phenomenon. REGENXBIO appealed.
After analyzing precedents including the Supreme Court’s decisions in Chakrabarty, Myriad, and Funk Brothers as well as the Federal Circuit’s decision in ChromaDex, the Federal Circuit reversed and remanded.
As part of its analysis, the Federal Circuit considered “whether the claimed host cells have ‘markedly different characteristics’ and have ‘the potential for significant utility’ from that which is naturally occurring.” In answering that inquiry and considering the natural phenomenon exception to eligibility, the court concluded that “the claims here are more analogous to the eligible claims in Chakrabarty and Myriad than the ineligible claims in Funk Brothers, Myriad, and ChromaDex.”
The district court had relied on Funk Brothers, but the Federal Circuit ruled that the claims at issue here were distinguishable from those claims because “the claims here are not merely directed to repackaging products of nature.” The involved techniques “fundamentally creat[e] a cell containing a molecule that could not form in nature on its own.”
The Federal Circuit also held that “the claimed composition here has ‘the potential for significant utility.’” The court specifically noted that courts “may consider whether the claimed composition has ‘the potential for significant utility’ even if that utility is only implicit—as it clearly is here.”
At bottom, the Federal Circuit concluded that “the claimed host cells here contain a recombinant nucleic acid molecule that, by definition, is markedly different from anything occurring in nature. The claimed host cells are, therefore, not patent-ineligible claims to naturally occurring subject matter.”