Synopsys, Inc. v. Real Intent, Inc.

Summary

The United States District Court for the Northern District of California addresses post-trial motions in a copyright and breach-of-contract dispute concerning electronic design automation software. The court grants in part and denies in part Real Intent’s motion for judgment as a matter of law, holding that the Copyright Act preempts the contract claim based on incorporation of Synopsys commands and vacating the related lost-profits award. The court does not disturb the jury’s unjust-enrichment award for the DesignWare breach and denies Synopsys’s motions for a permanent injunction and new trial as moot.

Holdings

1. The court could consider Real Intent's post-trial preemption argument because the specific breach-by-breach preemption issue had not been resolved at summary judgment and the trial created a more fully developed evidentiary record.
2. The Copyright Act preempted the Incorporation Breach because, as pursued at trial, the contractual theory was based solely on copying and incorporating Synopsys's copyrighted commands, rights equivalent to the exclusive rights protected by copyright.
3. Unjust enrichment measured by costs avoided was an available remedy for the DesignWare Breach.
4. Substantial evidence supported the jury's $297,500 award for saved research-and-development costs arising from the DesignWare Breach.
5. The court did not reach the foreseeability challenge because it vacated the lost-profits award on copyright-preemption grounds.

Questions Presented

1. Whether the court could consider Real Intent's copyright-preemption argument after summary judgment and trial.
2. Whether the Incorporation Breach, as presented to the jury and as the basis for Synopsys's lost-profits claim, was preempted by the Copyright Act.
3. Whether unjust enrichment based on avoided research-and-development costs was an available remedy for the DesignWare Breach.
4. Whether substantial evidence supported the jury's $297,500 unjust-enrichment award for the DesignWare Breach.
5. Whether Real Intent was entitled to judgment as a matter of law on foreseeability of Synopsys's lost profits.

Disposition

vacated