Edwards Lifesciences AG v. CoreValve, Inc.
United States Court of Appeals for the Federal Circuit
699 F.3d 1305 (2012)
Edwards (plaintiff) held a patent on a transcatheter heart valve and won a jury verdict that CoreValve (defendant) infringed it, along with damages and a reasonable royalty; the district court denied Edwards a permanent injunction, reasoning Edwards wouldn't suffer irreparable harm because it had already relinquished market exclusivity by licensing a competitor and had lost market share before the infringement even began, and relying on CoreValve's stated plan to relocate manufacturing to Mexico, which would end the infringement anyway. Edwards appealed, contending it had not actually licensed the patent to a competitor, had not yet lost market share since the FDA hadn't even approved U.S. sales, and that CoreValve had in fact kept manufacturing the infringing valves in California despite its representations.
Whether a successful patent plaintiff is entitled to injunctive relief against future infringement when equitable considerations weigh in favor of such relief.