Agrizap, Inc. v. Woodstream Corp.
Agrizap, Inc. has sued Woodstream Corporation in the United States District Court for the Eastern District of Pennsylvania for fraudulent misrepresentation and infringement of U.S. Patent No. 5,949,636 (the ’636 patent), which pertains to an electronic rodent-killing device. Woodstream appeals the district court’s denial of its motion for judgment as a matter of law (JMOL) for no fraudulent misrepresentation. Woodstream also appeals the denial of its JMOL motion for invalidity and unenforceability. Agrizap cross-appeals the district court’s final judgment of noninfringement.
Because sufficient evidence supports the jury’s verdict finding Woodstream liable for fraudulent misrepresentation and the trial evidence provides a reasonable basis for the jury’s attendant award of damages, we affirm. Though we defer to the jury for its fact findings on obviousness, we ultimately conclude that, despite those findings, the patent claims in dispute are invalid for obviousness and thus reverse the district court’s denial of Woodstream’s JMOL in that respect. As our decision on those issues completely resolves this case, we decline to address the other arguments as to patent infringement, invalidity, or unenforceability.
