Wordtech Sys., Inc. v. Integrated Networks Solutions, Inc., No.09-1454, concerned a patent infringement suit against defendant and its two employees, related to patents involving technology for automated duplication of compact discs, the court reversed the judgment of the district court for the most part, except the district court's denial of defendants' motion for leave to amend. .
First, the court held that the district court's denial of defendants' Rule 59(a) motion was improper as the jury's verdict of the two employees' individual liability of direct infringement, despite the lack of instructions on defendant's existence or piercing its corporate veil, was plain error that requires a new trial. Next, the court also reversed the jury verdict of individual liability for inducement as it involved a mistake of law. Further, the court held that the district court's legal error in presenting the contributory infringement issue with respect to individual liability of the two employees to the jury requires a new trial.
And lastly, because the verdict was clearly not supported by the evidence and was based on only speculation or guesswork, district court's denial of defendants' Rule 59(a) motion is reversed and remanded for a new trial on damages.