Robert Bosch LLC v. Pylon Manufacturing Corp.
United States Court of Appeals for the Federal Circuit
659 F.3d 1142 (2011)
Robert Bosch LLC (Bosch) (plaintiff) owned patents on beam-type windshield-wiper blades and lost its Wal-Mart distribution account to Pylon Manufacturing (Pylon) (defendant), a direct competitor, after Bosch failed to deliver blades on time. A jury found Pylon had infringed Bosch's patents, and Bosch sought a permanent injunction, presenting expert testimony that losing the Wal-Mart account had cost it other customers and evidence that Pylon faced an elevated risk of bankruptcy, undermining its ability to pay a money judgment. The district court nonetheless denied the injunction, finding Bosch hadn't shown irreparable harm, and Bosch appealed.
Whether a successful patent-infringement plaintiff is entitled to a permanent injunction if it would suffer irreparable harm in the absence of equitable relief.