Holding that evidence relying on "25 percent rule of thumb," which was a tool used to approximate the reasonable royalty rate the manufacturer of patented product would be willing to offer to pay to the patentee during a hypothetical negotiation, was inadmissible under Daubert since it failed to tie a reasonably royalty base to facts of case at issue
Holding the settlement license agreement in question had "very little relation to demonstrated economic demand for the patented technology, and its probative value is greatly outweighed by the risk of unfair prejudice, confusion of the issues, and misleading the jury"; therefore, concluding the district court had abused its discretion in admitting the settlement agreement into evidence
Holding that evidence of royalty rates from licenses without a relationship to the claimed invention could not form the basis of a reasonable royalty calculation
Holding "damages for infringement may account for both lost sales and reduction of prices due to infringing competition," as "an infringer's activities do more than divert sales to the infringer [t]hey also depress the price of the patented product"
Holding that the district court did not abuse its discretion in denying enhancement of damages for willfulness, stating that: "the case was hard-fought, and that the jury could have found for Shell on the infringement and willfulness issues and could have awarded substantially less damages. In addition, the trial court weighed Shell's litigation behavior and found no reason for an award of enhanced damages."
Finding the district court's analysis of the reasonable royalty based on a prior negotiation between the parties "already built in apportionment" without analysis of the smallest salable unit