Wonderland Switzerland AG v. Evenflo Company, Inc., Appeal Nos. 2023-2043, -2233, -2326 (Fed. Cir. Dec. 17, 2025)

This week’s Case of the Week includes a potpourri of issues following a jury trial and issuance of a permanent injunction against Evenflo based on patents directed to child car seats.  The Federal Circuit reversed a finding of infringement as to a certain family of products, affirmed the infringement findings in other respects, reversed the issuance of a permanent injunction, and remanded for a new trial on willfulness.  Judge Reyna issued a dissent on the latter issue.

Wonderland asserted two patents against two different families of Evenflo child seats.  A jury found that Evenflo’s 4-in-1 seats and 3-in-1 seats infringe Wonderland’s patents.  After trial, the district court granted Wonderland’s motion for a permanent injunction.  Although Wonderland only sought a permanent injunction in relation to one of the patents, the district court enjoined activities relating to both patents.  The parties cross-appealed.

Evenflo first argued that its 4-in-1 products did not infringe one of the two patents, which recited a “seat back having a locking mechanism for selectively detachably connecting” the seat back to the seat assembly.  The Federal Circuit agreed.  In those products, the locking mechanism is entirely on the seat assembly, not the seat back.  Wonderland argued that those products infringe under the doctrine of equivalents.  But the Federal Circuit held there was insufficient evidence to support such a finding because “[i]t is . . . insufficient, under DOE, to argue the ‘overall . . . mechanism” is the same or that a different claim element (i.e., the seat assembly) contains the locking mechanism.”  Rather “[DOE] must be applied to individual elements of the claim, not to the invention as a whole.”

With respect to a variety of other infringement arguments, the Federal Circuit affirmed, finding substantial evidence supported the jury’s verdict.

With respect to the district court’s grant of injunctive relief, the Federal Circuit reversed.  With respect to one of the patents, the Court held the district court erred because “Wonderland expressly declined to request such relief. . . . Thus, it is an abuse of discretion to grant such an extraordinary remedy when a party did not request it.”  As for the other patent, the Court found error because there was insufficient non-speculative or non-conclusory evidence to support multiple of the factors needed for such relief.  Instead, Wonderland offered speculative and conclusory testimony from executives at Wonderland’s partner, Graco, including about supposed reputational injury and alleged lost sales of non-accused products.

Finally, Wonderland cross-appealed for a new trial on willfulness, arguing that the district court improperly excluded a particular email thread suggesting an internal belief within Evenflo that one of its products infringed one of the patents.  The district court believed the email thread’s probative value was outweighed by concerns of prejudice.  The Federal Circuit found that was an abuse of discretion, because the district court could have used limiting instructions or redactions to allow the jury to see the probative portions while avoiding portions that were prejudicial.  Judge Reyna dissented on this last point, opining that “the district court did not abuse its discretion” and that its “balancing of considerations under Fed. R. Evid. 403 was careful and comprehensive.”

The opinion can be found here.

By Nika Aldrich

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Micron Technology, Inc. v. Longhorn IP LLC, Appeal Nos. 2023-2007, -2095 (Fed. Cir. Dec. 18, 2025)

On review of what might be called a “troll toll,” the Federal Circuit dismissed Longhorn IP’s interlocutory appeal from the District of Idaho’s imposition of an $8 million bond under Idaho’s “Bad Faith Assertions of Patent Infringement Act,” Idaho Code §§ 48-1701 et seq.  The Act prohibits bad faith infringement assertions, and upon finding a “reasonable likelihood” of bad faith, requires the patent claimant to post a bond sufficient to cover the alleged infringer’s costs of defense and any potential penalties under the Act.  The Federal Circuit has found similar state laws pre-empted by federal patent law to the extent they may impact good faith infringement claims, which Longhorn argued was the case here.  However, the Court found it lacked jurisdiction over Longhorn’s appeal because the lower court’s bond order was not a final judgment, and because Longhorn otherwise was unable to show that the order was “injunctive” in nature; that it was an appealable collateral order; or that it was subject to mandamus relief.  In rejecting Longhorn’s arguments, the Court relied repeatedly on the fact that the Act permits waiver of the bond upon a showing that the patentee holds assets sufficient to cover the potential costs, and that Longhorn had neither attempted to make that showing nor adduced evidence that it could not.  In part because Longhorn had not shown that immediate appeal was its only avenue for relief, the Federal Circuit found it lacked appellate jurisdiction and dismissed.

The opinion can be found here.

By Jason A. Wrubleski

This article summarizes aspects of the law and does not constitute legal advice. For legal advice with regard to your situation, you should contact an attorney.