Halo Elecs., Inc. v. Pulse Elecs., Inc.

• Decision Date: 10 January 2013
• Docket Number: 2:07-cv-00331-PMP-PAL
• Citation: Halo Elecs., Inc. v. Pulse Elecs., Inc., 2:07-cv-00331-PMP-PAL (D. Nev. Jan 10, 2013)
• Parties: HALO ELECTRONICS, INC., Plaintiff, v. PULSE ELECTRONICS, INC. and PULSE ELECTRONICS CORPORATION, Defendants.
• Court: U.S. District Court — District of Nevada

HALO ELECTRONICS, INC., Plaintiff,

v.PULSE ELECTRONICS, INC. and PULSE ELECTRONICS CORPORATION, Defendants.

2:07-cv-00331-PMP-PAL

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

DATED: January 10, 2013

ORDER

Before the Court is Plaintiff Halo Electronics's ("Halo") Motion for the Entry of Judgment Following the Jury Verdict (Doc. #500), filed December 5, 2012. Defendants Pulse Electronics, Inc. and Pulse Electronics Corporation (collectively "Pulse") filed a Response (Doc. #501) on December 6, 2012. Halo filed a Reply (Doc. #502) on December 7, 2012.

Halo argues that pursuant to Federal Rule of Civil Procedure 58, judgment consistent with the jury's verdict should be entered immediately. Halo argues Rule 58 mandates prompt entry of a judgment on the jury verdict regardless of any outstanding issues. Pulse responds that the Court still must decide Pulse's equitable defenses and makethe legal determinations of obviousness and willfulness. Pulse argues these outstanding issues trigger the application of Rule 54(b), and Halo has not shown just cause for entering partial judgment. Halo replies that it is routine in patent cases for the clerk to automatically enter judgment on a jury verdict or for courts to enter judgments upon request by a party. Halo also argues the equitable defenses and questions of law are post-trial issues that should not delay the entry of judgment on the jury verdict.

Rule 58(b)(2) states that when a jury returns a special verdict the Court must promptly approve the form of the judgment and the clerk must promptly enter the judgment. This provision is subject to Rule 54(b), which gives the Court the discretion to "direct entry of a final judgment as to one or more, but fewer than all, claims or parties." The Court may exercise this discretion "only if the court expressly determines that there is no just reason for delay" in entering judgment. Fed. R. Civ. P. 54(b). "In determining whether just reason for delay of entry of judgment exists, courts consider such factors as the interrelationship of the claims so as to prevent piecemeal appeals." Duhn Oil Tool, Inc. v. Cooper Cameron Corp., 818 F. Supp. 2d 1193, 1231 (E.D. Cal. 2011) (citing AmerisourceBergen Corp. v. Dialysist West, Inc., 465 F.3d 946, 954 (9th Cir. 2006)).

Pulse's equitable defense claims and the questions of law which the Court must decide are unresolved trial issues with the potential to affect the findings in the jury's verdict. Therefore, due to these outstanding legal issues, there is...