Federal Circuit Vacates And Remands Infringement And Damages Judgment After Erroneous Verdict Form And Eligibility Analysis

In Ollnova Technologies Ltd., v. ecobee Technologies ULC, No. 2025-1045, 2025-1046 (Fed. Cir. June 4, 2026), the Federal Circuit vacated and remanded an infringement and $11.5 million damages judgment, vacated and remanded the jury’s patent eligibility determination for the ’495 patent, and affirmed the district court’s determination that the claims of the ’887 and ’371 patents were not directed to abstract ideas at Alice step one.

Ollnova sued ecobee alleging that ecobee’s smart thermostats infringed four patents covering wireless communications in building automation systems. The district court denied ecobee’s motion to dismiss, holding that the ’887 and ’371 patents were not directed to abstract ideas at Alice step one and that while the ’495 patent was directed to an abstract idea, factual disputes precluded resolution at Alice step two. The case proceeded to a jury trial, which found that ecobee infringed one patent although the verdict form did not specify which one. The jury also found that the ’495 patent was not directed to well-understood, routine, and conventional technology. The jury awarded $11.5 million to Ollnova. The district court denied ecobee’s post-judgment motions, and ecobee appealed.

The Federal Circuit first addressed the verdict forms. The court held that the district court abused its discretion by including on the verdict form a single infringement question covering all asserted patents because that did not ensure a unanimous verdict. It also determined that the jury instructions and verdict form related to patent eligibility for the ’495 patent were erroneous because they failed to identify that the claims were directed to an abstract idea and that this abstract idea could not supply the inventive concept. As a result, the court vacated and remanded for a new trial on infringement and damages for all patents and for further proceedings under Alice step two as to the ’495 patent.

On the merits, the Federal Circuit held that judgment as a matter of law of patent ineligibility for the ’495 patent was unwarranted because a reasonable jury could have found that the claimed dual-network architecture was not well-understood, routine, or conventional. The court also affirmed the district court’s determination that the claims of the ’887 and ’371 patents were not directed to an abstract idea because they claimed specific technological solutions to identified problems.