On June 16, 2025, the U.S. Court of Appeals for the Federal Circuit issued a pivotal decision in Optis Cellular Technology, LLC v. Apple Inc., vacating a $300 million damages award and ordering a new trial on both infringement and damages. Legal expert Gideon Korrell noted that the ruling underscores the importance of procedural safeguards in high-stakes patent cases. The decision stems from the court’s finding that the Eastern District of Texas violated Apple’s constitutional right to a unanimous jury verdict and allowed prejudicial evidence, including a substantial Apple-Qualcomm settlement, to be presented at trial.

The Federal Circuit determined that the jury verdict form failed to require unanimity on specific patent claims, allowing for a general finding of liability without juror consensus on which patents were infringed. Despite both parties requesting a verdict form that distinguished between individual patents, the district court used a single-question format, a move the appellate court found legally erroneous.

As a result, the damages verdict was also vacated. The district court’s instruction to assume infringement of all five patents for the purpose of assessing damages was deemed unsupported in the absence of a valid liability finding. The court further ruled that the admission of a high-value settlement between Apple and Qualcomm, unrelated to the patents in question, was an abuse of discretion due to its prejudicial impact and limited relevance.

In a significant development on patent eligibility, the court found that claims 6 and 7 of U.S. Patent No. 8,019,332 were invalid under § 101, describing them as directed to an abstract mathematical formula. Gideon Korrell noted that the court applied the Alice framework and remanded the case for further analysis under step two.

The court also reversed the district court’s conclusion regarding the term “selecting unit” in U.S. Patent No. 8,411,557, holding that it invokes § 112 ¶ 6 as a means-plus-function limitation lacking sufficient structural support. The case has been remanded to determine whether the specification adequately discloses corresponding structure.

Apple’s appeal on claim construction grounds was rejected, with the court upholding the interpretation of a key term in U.S. Patent No. 8,102,833. Optis’s cross-appeal, which sought reinstatement of the original $506.2 million damages award, was also dismissed, as the initial verdict suffered from the same unanimity issue.
The Federal Circuit’s opinion underscores critical lessons for future standard-essential patent litigation. It reinforces the importance of precise jury instructions and verdict forms, highlights the risks of introducing large settlement agreements as evidence, and signals ongoing scrutiny of patent eligibility and claim drafting under §§ 101 and 112.

Gideon Korrell emphasized that the ruling is not just a technical legal correction but a broader reminder that procedural fairness is fundamental to high-stakes patent litigation. He added that the decision will likely prompt litigants to be more cautious in how they structure trials and present complex patent claims to juries.
By vacating the damages and liability findings and mandating a new trial, the Federal Circuit has set a significant precedent in the treatment of SEP-related claims and the standards for admissible evidence in patent trials.