Opinions — Tuesday, February 17, 2026

The Federal Circuit affirmed the District of Minnesota's denial of Polygroup's motion for judgment as a matter of law (JMOL) of obviousness and for a new trial on damages following a jury verdict finding claim 15 of Willis Electric's U.S. Patent No. 8,454,186—covering pre-lit artificial Christmas trees with coaxial trunk connectors—infringed and not invalid, awarding Willis approximately $42.5 million in damages. The patent relates to modular artificial tree trunk sections that form simultaneous mechanical and electrical connections at any rotational orientation. After multiple rounds of inter partes review left only claim 15 viable for trial, Polygroup argued that no reasonable jury could find the claim nonobvious because a skilled artisan would have been motivated to modify a prior art tree (the Loomis GKI Tree) to use well-known coaxial barrel connectors for powering LED lights. The court held that substantial evidence supported the jury's finding of no motivation to combine, crediting Willis's expert testimony that such modification would require removing the prior art's alignment features and extensively redesigning connector housings, effectively abandoning the prior art's core teachings. On damages, Polygroup challenged the admissibility and methodology of Willis's damages expert, who calculated a $5 per-tree royalty based on various apportionment methods, but the court found no abuse of discretion in admitting the testimony or denying a new trial.

The decision clarifies the interplay between IPR proceedings under broadest reasonable interpretation and district court claim construction under Phillips in defining the scope of recoverable damages for dependent claims. Because the Patent Trial and Appeal Board had invalidated independent claim 10 under a broader construction than the district court applied (specifically, not requiring the one-step simultaneous mechanical-electrical connection functionality that the district court's construction demanded), the Federal Circuit held that Willis could recover damages for value attributable to that one-step functionality as part of claim 15's coaxial connector limitation. The court reaffirmed that apportionment to the patented feature does not require subtracting value from conventional elements when those elements contribute to the invention's overall value, emphasizing that the factual determination of what value is attributable to a claimed feature remains with the jury. The court's motivation-to-combine analysis underscores that evidence showing a combination would abandon a prior art reference's teachings can constitute substantial evidence against obviousness, even where individual components are well-known and industry trends favor certain technologies.