Multimedia Technologies Pte. Ltd. v. LG Electronics Inc.

United States District Court for the Eastern District of Texas, Marshall Division · February 7, 2025 · No. 2:22-cv-00494-JRG-RSP

Summary

This memorandum order from the U.S. District Court for the Eastern District of Texas addresses the defendants' motion to exclude the expert testimony of Justin Blok regarding patent damages. Applying Federal Rule of Evidence 702 and Daubert standards, the court evaluates whether the expert's methodology for calculating reasonable royalties and hypothetical negotiations is reliable. After analyzing arguments concerning the expert's reliance on survey data, a prior patent purchase agreement, a settlement license, and a failed joint venture, the court finds that any deficiencies relate to credibility rather than admissibility. Consequently, the court denies the motion to exclude the expert testimony.

Court
United States District Court for the Eastern District of Texas, Marshall Division
Jurisdiction
United States District Court for the Eastern District of Texas
Decision date
February 7, 2025
Docket number
2:22-cv-00494-JRG-RSP
Procedural posture
Defendants' motion to exclude expert testimony denied
Precedential value
non-precedential
Disposition
other

Topics

expert testimonydaubert standardpatent lawpatent infringementevidence

Practice areas

intellectual propertycommercial litigation

Questions Presented

  1. Whether the expert testimony of Justin Blok is admissible under Fed. R. Evid. 702
  2. Whether the expert's methodology for calculating reasonable royalties is reliable

Holdings

  1. The motion to exclude the expert testimony is denied; the expert's testimony is admissible.

Key quotations

When, as here, the parties’ experts rely on conflicting sets of facts, it is not the role of the trial court to evaluate the correctness of facts underlying one expert’s testimony.
Vigorous cross‑examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.

Factual background

Multimedia Technologies purchased the asserted patents from Flextronics in 2022 and later licensed them to Samsung. The parties disputed the methodology of expert Justin Blok's damages calculations, including royalty base apportionment, market willingness‑to‑pay percentages, and consideration of purchase and licensing agreements. The court evaluated whether Blok's testimony satisfied Fed. R. Evid. 702.

Court Document

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