Romag Fasteners, Inc. v. Fossil, Inc.

Summary

The United States Court of Appeals for the Federal Circuit recalled its mandate and reinstated the appeal following the Supreme Court’s vacatur and remand in light of SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC. It vacated the district court’s reduction of Romag’s patent damages based on laches, remanded for correction of the damages amount, and reinstated the prior decision affirming the denial of Fossil’s profits.

Holdings

1. Under the Supreme Court's decision in SCA Hygiene, laches is not a defense to patent infringement within the statutory period.
2. The June 27, 2014 judgment reducing Romag's patent damages by eighteen percent due to laches is vacated, and the case is remanded for correction of the damages judgment amount.
3. The Federal Circuit reinstated sections II and III of its earlier decision affirming the district court's judgment declining to award Fossil's profits.

Questions Presented

1. Whether the Federal Circuit should recall its mandate and reinstate the appeal after the Supreme Court's remand.
2. Whether laches may serve as a defense to patent infringement within the statutory period after SCA Hygiene.
3. Whether the prior Federal Circuit judgment affirming the denial of Fossil's profits should be reinstated.

Disposition

reversed_and_remanded