## Facts

- Imperium IP Holdings (Cayman), Ltd. owned patents directed to image-sensor and image-processing technology used in digital imaging devices: U.S. Patent Nos. 6,271,884, 7,092,029, and 6,836,290.
- Imperium sued Samsung entities in the Eastern District of Texas, alleging that Samsung smartphones and tablets infringed asserted claims of the patents.
- After a jury trial (verdict Feb. 8, 2016), the jury found infringement of specified claims of the ’884 and ’029 patents, found willful infringement, and awarded reasonable-royalty damages totaling $6,970,380.50 (approximately $0.04 per unit for the ’884 patent and $0.02 per unit for the ’029 patent).
- The jury found claim 10 of the ’290 patent invalid for obviousness.
- The court entered judgment, including enhanced damages based on willfulness.
- Samsung moved post-trial for JMOL and/or a new trial, challenging infringement, validity, willfulness, damages, expert testimony, and the effect of discovery sanctions.
- Imperium sought attorneys’ fees and non-taxable costs under 35 U.S.C. § 285.

## Issues

1. Whether substantial evidence supported the jury’s findings of infringement, no invalidity (as to the ’884 and ’029 claims), willful infringement, and the reasonable-royalty damages award.
2. Whether Imperium’s technical and damages expert testimony was inadmissible or insufficient because the experts did not present all underlying materials or allegedly used improper methods.
3. Whether discovery-related sanctions and related evidentiary rulings unfairly prejudiced Samsung such that a new trial was required.
4. Whether Imperium was a “prevailing party” and the case was “exceptional” warranting fees and non-taxable costs under 35 U.S.C. § 285.

## Decision

- The court denied Samsung’s motions for JMOL and for a new trial, leaving the jury’s infringement, validity, willfulness, and damages findings intact.
- The court held that Imperium’s expert testimony provided legally sufficient evidentiary support and that Samsung’s criticisms went to weight, not admissibility.
- The court upheld its discovery sanctions and found no trial unfairness warranting a new trial.
- The court determined Imperium was the prevailing party and found the case exceptional under § 285, granting Imperium’s request for attorneys’ fees and non-taxable costs (with amounts to be addressed separately).

## Legal Principles

- JMOL is improper where, viewing the record under Rule 50 standards, a reasonable jury had a legally sufficient evidentiary basis for its verdict; the court may not reweigh competing trial evidence.
- Expert opinions may be based on materials reasonably relied upon in the field, even if every underlying item is not admitted or shown to the jury, so long as the testimony is subject to cross-examination and otherwise satisfies evidentiary rules.
- Post-trial challenges to a reasonable-royalty award fail where the expert’s framework and inputs are supported by record evidence and the jury’s award falls within the evidentiary range presented at trial.
- Discovery sanctions are reviewed for fairness and proportionality; sanctions within the court’s discretion do not justify a new trial absent a showing that they deprived the sanctioned party of a fair opportunity to present its case.
- Under 35 U.S.C. § 285, a fee award requires (1) prevailing-party status and (2) a finding that the case is exceptional based on the totality of circumstances.

## Conclusion

The district court upheld the jury’s findings that Samsung infringed the asserted ’884 and ’029 patent claims, that the claims were not proven invalid, that Samsung’s infringement was willful, and that the damages award was supported by substantial evidence; it also upheld discovery sanctions and granted Imperium attorneys’ fees and non-taxable costs after finding Imperium the prevailing party and the case exceptional under § 285.


Imperium IP Holdings (Cayman), Ltd. v. Samsung Elecs. Co., 259 F. Supp. 3d 530 (E.D. Tex. 2017)