Willowood LLC
Willowood LLC
Willowood LLC
v.
2018-1614, 2018-2044
______________________
Pharm., Inc. v. Iancu, 913 F.3d 1351, 1356 (Fed. Cir. 2019);
Mohsenzadeh v. Lee, 790 F.3d 1377, 1381 (Fed. Cir. 2015).
The Fourth Circuit reviews the grant of a motion for sum-
mary judgment de novo, viewing all evidence in the light
most favorable to the non-moving party. Amdocs (Israel)
Ltd. v. Openet Telecom, Inc., 761 F.3d 1329, 1337–38 (Fed.
Cir. 2014) (citing Ramos v. S. Maryland Elec. Co–op., Inc.,
996 F.2d 52, 53 (4th Cir. 1993)). The Fourth Circuit re-
views a district court’s post-verdict JMOL decisions de
novo, determining whether the jury’s verdict is supported
by substantial evidence. LifeNet Health v. LifeCell Corp.,
837 F.3d 1316, 1322 (Fed. Cir. 2016) (citing Carolina
Trucks & Equip., Inc. v. Volvo Trucks of N. Am., 492 F.3d
484, 488 (4th Cir. 2007)). The Fourth Circuit reviews a dis-
trict court’s pre-verdict grant of JMOL de novo, viewing all
evidence in light most favorable to the non-moving party
and considering whether a reasonable jury could find for
the non-moving party. ActiveVideo, 694 F.3d at 1319 (cit-
ing Brown v. CSX Transp., 18 F.3d 245, 248 (4th Cir.
1994)).
We review questions of patent law under Federal Cir-
cuit law. Ericsson, Inc. v. D-Link Sys., Inc., 773 F.3d 1201,
1214 (Fed. Cir. 2014). We review a jury’s findings on ques-
tions of fact, such as infringement and damages, for sub-
stantial evidence. Power Integrations, Inc. v. Fairchild
Semiconductor Int’l, Inc., 711 F.3d 1348, 1377 (Fed. Cir.
2013). We review a district court’s decisions concerning
damages methodologies for abuse of discretion. ActiveVi-
deo Networks, Inc. v. Verizon Commc’ns, Inc., 694 F.3d
1312, 1332 (Fed. Cir. 2012) (citing Lucent Techs., Inc. v.
Gateway, Inc., 580 F.3d 1301, 1310 (Fed. Cir. 2009)).
We apply copyright law as interpreted by the regional
circuit. Amini Innovation Corp. v. Anthony Cal., Inc., 439
F.3d 1365, 1368 (Fed. Cir. 2006). Interpretation of the
rights granted by the Copyright Act is a question of law
that the Fourth Circuit reviews de novo. See Rosciszewski
v. Arete Assocs., Inc., 1 F.3d 225, 229 (4th Cir. 1993).
16 SYNGENTA CROP PROTECTION, LLC v. WILLOWOOD, LLC
V. Willowood’s Cross-Appeal
Willowood conditionally cross-appeals the district
court’s denial of its motion to exclude the testimony of Syn-
genta’s expert concerning damages for infringement of the
Compound Patents. Cross-Appellant’s Br. 56–66. Syn-
genta responds that Willowood’s cross-appeal is procedur-
ally improper because it does not seek to expand the scope
of the judgment below. Appellant’s Resp. Br. 49–51. We
need not decide these issues because Willowood’s cross-ap-
peal is conditional on our reversal of the judgment concern-
ing the Compound Patents, and we affirm the district court
in that respect.
CONCLUSION
We have considered the parties’ remaining arguments
and find them unpersuasive. We conclude that the district
court did not provide an adequate analysis of the potential
conflict between FIFRA and the Copyright Act for us to de-
termine whether such a conflict truly exists. We also con-
clude that the district court erred by imposing a single-
entity requirement on the performance of a patented pro-
cess under § 271(g). We agree with the district court in all
other respects. We therefore affirm-in-part, reverse-in-
part, vacate-in-part, and remand for further proceedings
consistent with this opinion.
AFFIRMED-IN-PART, REVERSED-IN-PART,
VACATED-IN-PART, AND REMANDED
COSTS
Each party shall bear its own costs.