Microchip Technology Incorporated v. Aptiv Services US LLC

Filing 369

MEMORANDUM. Signed by Judge Joshua D. Wolson on 5/6/2022. (cna, )

Case 1:17-cv-01194-JDW Document 369 Filed 05/06/22 Page 1 of 2 PageID #: 14657

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MICROCHIP TECHNOLOGY
INCORPORATED,

Case No. 1:17-cv-01194-JDW

Plaintiff,
v.
APTIV SERVICES US LLC,
Defendant.
MEMORANDUM
On April 7, 2022, the Court asked Microchip if it dropped the ‘708 Patent claims, and
Microchip confirmed that it had. During trial, neither Party presented any evidence on the ‘708
Patent. Both focused solely on claims 23–25 of the ‘243 Patent.
The Court provided the Parties with a verdict form that only referenced claims 23–25 of
the ‘243 Patent. The Parties had an opportunity to object and did not do so. The Court sent a final
verdict form that only referenced claims 23–25 of the ‘243 Patent to the jurors. The jury decided
that Aptiv did not infringe claims 23–25 of the ‘243 Patent and that claims 23–25 were valid.
Aptiv now argues that the Court should enter a judgment in favor of Aptiv with respect to
Microchip’s infringement claims for the ‘708 Patent and the entirety of the ‘243 Patent.
The Court will not do so. The nub of this dispute is that Aptiv wants to maximize the
estoppel effect of this judgment. But the effect of Microchip abandoning its claims with respect
to the ‘708 Patent and certain ‘243 Patent claims is an issue that the Court need not decide. The
Court merely has to decide what the form of judgment says. Should Microchip assert claims
against Aptiv that Microchip elected not to present to the jury, the Parties can present these same
arguments at that time.

Case 1:17-cv-01194-JDW Document 369 Filed 05/06/22 Page 2 of 2 PageID #: 14658

For now, the Court will enter a form of judgment consistent with the verdict form sent to
the jurors. Such an approach is the norm. See Cordis Corp. v. Bos. Sci. Corp., 431 F. Supp. 2d
442, 450 (D. Del. 2006) (entering a judgment that excluded dismissed claims); (compare D.I. 3673 (verdict form) with 367-4 (accompanying form of judgment); see also D.I. 367-6 (entering
judgment “as set out in the verdict form.”).) Aptiv has not cited any case or authority to the
contrary, and the Court sees no reason to depart from the norm.
BY THE COURT:
/s/ Joshua D. Wolson
JOSHUA D. WOLSON, J.
May 6, 2022

2