Federal Circuit Reverses Car Seat Patent Injunction, Grants New Trial on Willfulness

"Following a trial in the district court, a jury determined that Evenflo's 3-in-1 and 4-in-1 seats infringed claim 1 of the '043 patent under the doctrine of equivalents (DOE), and that various models also infringed claims of the '951 patent. However, the jury concluded that Evenflo's infringement of the '043 patent was not willful. The district court subsequently granted Wonderland's motion for a permanent injunction and denied post-trial motions from both companies, leading to the cross-appeals."

"The U.S. Court of Appeals for the Federal Circuit (CAFC) on Wednesday issued a mixed, split, precedential ruling in Wonderland Switzerland AG v. Evenflo Company, Inc., reversing a permanent injunction and granting a new trial for willful patent infringement in a case between two child car seat manufacturers. The court found a district court judge abused his discretion both in granting an injunction based on speculative harm"

Wonderland Switzerland AG sued Evenflo in Delaware, asserting patents '043 and '951 covering car seat back mechanisms. A jury found Evenflo's 3-in-1 and 4-in-1 seats infringed claim 1 of the '043 patent under the doctrine of equivalents and found infringement of claims of the '951 patent, but found no willfulness for the '043 infringement. The district court granted a permanent injunction and denied post-trial motions. The Federal Circuit reversed the injunction, held the doctrine of equivalents must be applied to individual claim elements, and ordered a new trial on willfulness. The court found the district court abused its discretion by excluding a key email chain asking how to "ingeniously" avoid a patent. The opinion was precedential and split.

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