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Top Damage Awards in 2024: One Toppled, Others Boosted, and One Trimmed

January 12, 2025

Juries returned a series of sizable damages awards in patent infringement suits this past year. However, subsequent developments in some of the cases with 2024’s largest verdicts underscore how a jury verdict is frequently not the final word on damages—with the year’s top verdict, an $847M award in East Texas, falling apart entirely due to a post-trial ruling; four others increased at final judgment with the addition of interest, in one case this past week; and another trimmed by a posttrial noninfringement ruling. Here, RPX takes a look back at these and the other top ten verdicts of 2024.

Top Ten Damage Awards in 2024

Damages Awarded Plaintiff Defendant District
$847M General Access Solutions, Ltd. (f/k/a Access Solutions, Ltd.) Verizon E.D. Tex.
$525M Kove IO, Inc. Amazon N.D. Ill.
$445M Netlist Micron Technology E.D. Tex.
$315.7M SPEX Technologies, Inc. Western Digital C.D. Cal.
$262M MR Technologies, GmbH Western Digital C.D. Cal.
$242M IPA Technologies Inc. Microsoft D.  Del.
$192M Mojo Mobility, Inc. Samsung E.D. Tex.
$151.1M Centripetal Networks Palo Alto Networks E.D. Va.
$121.95M AlmondNet, Inc. Amazon W.D. Tex.
$118M Netlist Samsung E.D. Tex.
$115.2M Sarepta Therapeutics, University of Western Australia Nippon Shinyaku D. Del.

1. General Access Solutions v. Verizon: $847M; Overturned Posttrial

Last June, an Eastern District of Texas jury returned an $847M verdict against Verizon (Verizon Wireless and multiple other subsidiaries) and in favor of General Access Solutions, Ltd. (f/k/a Access Solutions, Ltd.) (GAS), a plaintiff that public records reveal has the backing of an unnamed litigation funder. The jury awarded $583M in damages for the infringement of a first patent-in-suit (7,230,931) and $264M for infringement of a second (9,426,794). Despite “great respect for a jury’s considered verdict”, Chief Judge Rodney Gilstrap vacated that verdict in October, concluding that it was “against the great weight of the evidence to such a material degree that a new trial is necessary”. The court did so in a ruling on a motion filed by Verizon for a new trial, also pointing to multiple arguments that the defendants made in their parallel motion for judgment as a matter of law with respect to infringement, invalidity, and damages.

However, that new trial did not ultimately take place. On December 5, 2024, the day before that trial was set to begin, the Patent Trial and Appeal Board (PTAB) invalidated both of the tried claims (28 and 29) from the ‘931 patent, which as noted above accounted for the $583M portion of the jury award. The parties notified the court of a settlement shortly thereafter.

This is just the latest in a series of chart-topping jury verdicts that have fallen after the fact for one reason or another. For instance, the largest damage award of 2023, a $469M verdict returned for ClearPlay (a provider of content filtering technology) against DISH over functionality allowing users to skip commercials, was overturned weeks after trial by Utah District Judge David Nuffer, who in March 2023 granted judgment as a matter of law (JMOL) of noninfringement for the accused products. The resulting appeal—after being “deactivated” for a time pending the outcome of certain post-judgment motions in the litigation below—is currently being briefed.

While the top damage award of 2022—totaling $948M for VLSI Technology LLC against Intel—has survived, an even larger one from the year before has not. A $2.18B verdict in another case between those same parties, the second largest damage award ever issued by a jury, was toppled in December 2023 by the Federal Circuit, which wiped out a Texas jury’s finding of infringement for one patent; reversed and remanded as to damages for a second patent; and also revived the defendant’s license defense in that case, in which Intel argues that it has a license to VLSI’s portfolio due to the acquisition of Finjan, Inc. by VLSI’s parent, Fortress Investment Group LLC. Additionally, both patents from that verdict were invalidated by the PTAB in set of closely watched inter partes reviews (IPRs) filed by two third parties, OpenSky Industries and Patent Quality Assurance (PQA), both of which were roiled by accusations of gamesmanship from both petitioners that led now-former USPTO Director Kathi Vidal to impose a series of sanctions against them.

Intel’s license defense is set for trial before Western District of Texas Judge Alan D. Albright in May 2025, amid further intrigue in a related case filed by VLSI against PQA.

2. Kove IO v. Amazon: $525M; $672.7M Final Judgment with Interest Added

The second highest award of 2024 was issued for inventor-controlled Kove IO, Inc. in its litigation against Amazon (Amazon Web Services). On April 10, an Illinois jury found that the company had infringed three distributed network storage patents through its Simple Storage System (S3) and DynamoDB products and awarded $525M in damages, though it also determined that this infringement had not been willful. Litigation leading up to that trial dealt in part with the impact of certain ex parte reexaminations (EPRs) against the asserted patents, after the district judge found that the patent owner had disclaimed certain subject matter through statements made in those proceedings. The defendant’s appeal of the resulting final judgment—which added $147.7M in interest, bringing the total to $672.7M in total damages—is pending before the Federal Circuit, which has extended the deadline for the opening brief to February 13, 2025.

3. Netlist v. Micron Technology: $445M

In May 2024, an Eastern District of Texas jury returned a verdict awarding Netlist a combined $445M for the infringement of two memory patents by Micron Technology in one of several cases between those two parties. The jury also found the infringement to have been willful, but the bulk of its award corresponds to a patent claim that the PTAB canceled in an IPR the month prior. Briefing on the parties’ posttrial motions, which have yet to be decided, concluded in late October.

More on the litigation between those parties, including the May infringement verdict, can be found here.

4. SPEX Technologies v. Western Digital: $315.7M; $552.7M Final Judgment with Interest Added

On October 18, in a long-running case filed back in 2016, a Central District of California jury returned a verdict in favor of funded plaintiff SPEX Technologies, Inc., finding that Western Digital infringed a single claim from one patent generally related to securing a peripheral computing device. The jury apportioned damages for the provision of two accused hard disk drives, roughly $194M for the My Book and roughly $122M for the Ultrastar He10. On January 8, 2025, the court issued a final judgment that imposed prejudgment interest of $160M and $86M for those respective products, for a total damage award of $552.7M.

The eight-year run of this case included two stays, a trip up to the Federal Circuit, and the decimation of SPEX’s planned damages case, forcing the plaintiff to present a facts-only theory without the benefit of expert opinion. Further background is available here.

5. MR Technologies v. Western Digital: $262M; $379.7M with Interest Added

On July 26, a Central District of California jury returned a verdict in favor of MR Technologies, GmbH, finding that Western Digital infringed two of the plaintiff’s patents, which broadly relate to hard disk drive magnetic recording media. The jury awarded the plaintiff more than $262M in damages for that infringement, to which District Judge James V. Selna added prejudgment interest of around $117M in a judgment for the plaintiff entered on August 14. On November 27, the court granted the parties’ stipulation to stay the execution of that judgment pending the outcome of Western Digital’s posttrial motions.

See here for background on this campaign, including the case tried last year and another that SPEX filed against the same defendant soon after the aforementioned final judgment.

6. IPA Technologies v. Microsoft: $242M

This past May, IPA Technologies Inc., a subsidiary of Wi-LAN Inc. (WiLAN), won a Delaware verdict finding that Microsoft infringed three claims from a single patent generally related to speech-based control over electronic resources through the provision of the Cortana digital assistant. The jury indicated that Microsoft failed to prove those claims anticipated by certain prior art (“the WARREN implementation of the RETSINA system”) and awarded $242M in damages. One month later, the parties notified the court that they had reached a settlement. Meanwhile, district court litigation against Alphabet (Google) remains stayed to await IPA’s appeals from adverse final written decisions handed down in remand PTAB proceedings. 

7. Mojo Mobility v. Samsung: $192M

In September, an Eastern District of Texas jury returned a verdict for Mojo Mobility, Inc. in a case filed against Samsung back in October 2022 over a set of wireless charging patents. The jury found all eight claims (from five patents) infringed, willfully, and not proven invalid (as obvious), awarding a lump sum payment of just over $192M. The additional, equitable defense of prosecution laches remained available to Samsung; this summer, Chief Judge Rodney Gilstrap adopted a report and recommendation denying to Mojo Mobility partial summary judgment on the issue because genuine disputes of material fact exist both as to whether alleged delays in prosecution of the asserted patents were reasonable and as to whether those delays prejudiced Samsung, by in the meantime “investing in, working on, or using the accused technology” in connection with, for example, the Galaxy S6. A bench trial was held on that issue on December 19, 2024, and the parties both submitted proposed findings of fact and conclusions of law, doing so under seal, on January 9.

8. Centripetal Networks v. Palo Alto Networks: $151.1M; Lowered to $116.3M

One significant verdict from 2024 that was later slimmed down by the district court came in litigation filed by Centripetal Networks against Palo Alto Networks (2:21-cv-00137). On January 31, an Eastern District of Virginia jury returned an infringement verdict for the plaintiff, finding that certain Palo Alto Networks cybersecurity products infringed four Centripetal patents, down from the 13 previously at issue—the case having been trimmed significantly by the Patent Trial and Appeal Board (PTAB) in 2023. Additionally, the jury awarded Centripetal $151.1M in lump-sum damages but determined that Palo Alto Networks’s infringement had not been willful. The jury also found that three of the patents were not “well-understood, routine, and conventional”, based on which those patents apparently survived an Alice challenge from the defendant in a sealed posttrial ruling. In October, though, another posttrial decision saw District Judge Elizabeth W. Haynes reverse the verdict as to infringement of one of the four patents, due to which the court lowered the total damage award to $116.3M. The parties both appealed in November.

The above verdict followed a series of significant setbacks for the plaintiff in the past few years in another suit: After the Federal Circuit overturned a $2.7B judgment in its case against Cisco in June 2022 due to a conflict held by the now-deceased district judge, another district judge reversed the underlying judgment of infringement in December 2023.

8. AlmondNet v. Amazon: $121.95M; $136.6M Final Judgment with Interest Added

Last June, a Western District of Texas jury returned a verdict for AlmondNet, Inc. in a suit that it filed with its subsidiary Intent IQ, LLC against Amazon(Amazon.com Services, Amazon Web Services) in August 2021. The jury found two claims, one from each of two tried patents, infringed and not proven invalid, awarding $121.95M in damages, well below the plaintiffs’ reported ask. Presiding Judge Alan D. Albright also submitted to the jury the “issue as to conventionality” of the asserted claim of one of the patents, which patent claim the court had ruled in pretrial proceedings is directed to an abstract idea under step oneof the Alice test. The jury answered that question on the verdict form—whether a skilled artisan would consider the patent’s subject matter to be “well-understood, routine, and conventional” at its priority date, as relevant for Alice step two—in the negative. Amazon has argued that no reasonable jury could have reached that result in a renewed motion for judgment as a matter of law.

The parties also disputed the amount of interest to be added to the final judgment: AlmondNet sought $210M, but Amazon argued that the plaintiff was wrong on two points: It could not look back to 2012 to calculate interest due to its allegedly strategic delay in suing Amazon, and it should have to use the one-year Treasury-Bill rate, rather than the prime rate. At most, Amazon asserted, the court should award $14.49M. The court agreed with Amazon, resulting in a final judgment of $136.6M.

9. Netlist v. Samsung: $118M

On November 22, 2024, an Eastern District of Texas jury returned another verdict for Netlist, this one awarding the plaintiff a combined $118M for the infringement of three memory patents, this time by Samsung. The bulk of the award is associated with a single patent claim that was canceled in an April 17, 2024 final written decision from the PTAB. Most ($425M worth) of a $445M verdict from earlier this year, against Micron Technology, stems from that same patent; the judgment based on that prior verdict, as well as the final written decision from the PTAB, are now on appeal.

Meanwhile, earlier in May, a Central District of California jury found both that a provision of a November 2015 Joint Development and License Agreement (JDLA) between Netlist and Samsung required the latter to supply certain products to Netlist “without limitation to” a joint development project between the two and that Samsung’s breach of that provision is material. These findings are key to a multifront patent infringement battle between Netlist and Samsung because the JDLA grants them cross-licenses to each other’s patent portfolios.

Coverage of the May verdict in the latter case and another in a Netlist infringement case against Micron can be found here, with additional prior background here.

10. Nippon Shinyaku v. Sarepta Therapeutics: $115.2M

On December 20, a Massachusetts jury issued two verdicts in litigation between Nippon Shinyaku and Sarepta Therapeutics, competing providers of treatments for Duchenne muscular dystrophy asserting patents against one another. At that point in the litigation, infringement had already been established, so the verdicts addressed other issues—the first, validity and willfulness. In that verdict, the jury found that Sarepta had shown the asserted claim from a Nippon Shinyaku patent to be invalid, that Nippon Shinyaku had not shown a Sarepta patent to be invalid, but that Nippon Shinyaku’s infringement of that patent had not been willful. The second verdict dealt solely with damages, the jury awarding $115.2M to Sarepta and the University of Western Australia (or UWA, the owner of the patent asserted by licensee Sarepta). After the trial, on January 3, the parties also stipulated that Sarepta and UWA were entitled to reasonable royalty damages of $841.5K for sales outside the US.

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