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Last week, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion in Finesse Wireless LLC v. AT&T Mobility LLC, No. 24-1039 (Sept. 24, 2025), reversing the district court's denial of judgment as a matter of law (JMOL) of noninfringement and vacating the jury's award of over $160 million in damages.
Finesse sued AT&T for infringement of two patents relating to methods of reducing interference in radios. Finesse's first patent claims a method of reducing intermodulation product (IMP) interference by sampling "signals of interest" and "interference generating signals," isolating the two signal types, and cancelling out the interference generating signals. Finesse's second patent claims a method of reducing IMP interference by creating IMP cancellation signals through seven digital multiplications of three signals.
At trial, regarding the first patent, Finesse's infringement expert testified that he mapped the signals of interest to a downlink transmit reference and mapped the interference generating signals to a modeled passive intermodulation products (PIM) path. The expert later changed his testimony to identify "x1" and "x2" but did not explicitly map "x1" and "x2" to the signals of interest and interference generating signals. Regarding the second patent, Finesse's expert testified that the accused radios performs the claims multiplications but relied on a document identifying only three multiplications.
AT&T moved for JMOL. The district court denied the motion, ruling for the first patent that there was sufficient evidence that the accused radios' receivers sample both the "signals of interest" and "interference generating signals" and therefore infringe Finesse's patent. For the second patent, the district court denied JMOL in part because the three multiplications corresponded to some of the seven claimed multiplications.
The Federal Circuit reversed. On the first patent, the Court reversed because the expert testimony was unclear. The Court held that even if the expert mapped x1 and x2 to the signals of interest and interference generating signals, he did not explain his contradictory testimony, and his testimony was insufficient to support the jury's verdict. On the second patent, the Court reversed because neither the expert nor the document indicated how the three multiplications mapped onto the seven multiplications. Therefore, no reasonable jury could have found that the accused radios practiced the seven claimed multiplications.
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