Court finds substantial evidence supports jury's verdict of infringement
Becton Dickinson and Company v. Tyco Healthcare Group LP, No. 02-1694-GMS, October 14, 2008.
Sleet, C.J. The Court denies defendant’s motion for judgment as a matter of law having ruled that substantial evidence was presented to support the jury’s infringement verdict.
Court considers defendant’s renewed motion for judgment as a matter of law. Citing Pannu v. Iolab Corp., the Court notes that to prevail, defendant must show that the jury’s findings, presumed or express, are not supported by substantial evidence or, if they were, the legal conclusions implied by the jury’s verdict cannot be supported. Defendant challenges the jury’s findings that it infringed the ‘544 patent which invention is a safety needle shield that is used to prevent accidental needle sticks to health care workers. The only issue for the jury to decide at trial was whether defendant’s safety needle devices contained the “spring means” element recited in plaintiff’s claims. Having reviewed the evidence the Court concludes that substantial evidence (including circumstantial evidence) was presented such that it was reasonable for the jury to infer that the defendant’s devices contain a spring mechanism as defined in plaintiff’s claims. Therefore, the Court denies defendant’s motion for judgment as a matter of law.
