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Kaufman v. Microsoft Corp.

Michael Philip Kaufman owns now-expired U.S. Patent No. 7,885,981, on which he is a co-inventor. The patent describes and claims methods for using a computer to automatically generate an end-user interface for working with the data in a relational database. Mr. Kaufman brought the present action against Microsoft Corporation, asserting infringement of claims of the patent by Microsoft’s making and selling of its Dynamic Data product. A jury found Microsoft liable and awarded damages of $7 million to Mr. Kaufman. The district court upheld the verdict against Microsoft’s post-judgment challenges, Kaufman v. Microsoft Corp., No. 1:16-cv-02880, 2021 WL 242672, at *1 (S.D.N.Y. Jan. 25, 2021) (JMOL Order), and it also denied Mr. Kaufman’s motion to amend the judgment to include prejudgment interest, Kaufman v. Microsoft Corp., No. 1:16-cv-02880, 2021 WL 260485, at *1 (S.D.N.Y. Jan. 25, 2021) (Prejudgment Interest Order).

Microsoft and Mr. Kaufman both appeal. We reject Microsoft’s challenges and thus affirm the denial of Microsoft’s post-judgment motions. But we agree with Mr. Kaufman’s challenges and reverse the denial of prejudgment interest.

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