Versata Software, LLC v. Ford Motor Company

Versata Software, LLC v. Ford Motor Company The Federal Circuit held that the district court legally erred by categorically limiting Versata to a licensing-history reasonable royalty and precluding unjust-enrichment damages for trade secret misappropriation under the DTSA and MUTSA. It also held that the breach-of-contract damages award was supported by sufficient evidence and that Ford was not entitled to JMOL on trade secret liability. Although not a patent-merits decision, the precedential ruling is a useful Federal Circuit reminder that district courts cannot use prior licensing history to categorically bar statutory unjust-enrichment damages theories where trade secret claims travel with patent-related jurisdiction. Affirmed-in-part, reversed-in-part, vacated-in-part, and remanded. The court vacated the zero-dollar trade secret damages judgment and remanded for a new damages trial, reversed the reduction of contract damages and reinstated the $82.26 million jury award, and affirmed denial of Ford’s JMOL on trade secret liability. The district court had excluded Versata’s trade secret damages theories except for a reasonable royalty tied to the parties’ licensing history, then reduced the jury’s $22.386 million trade secret award to zero. The Federal Circuit held that both the DTSA and MUTSA expressly permit unjust-enrichment damages, and Sixth Circuit precedent did not require damages to be measured only by the parties’ license history. The court remanded for a new trade secret damages trial and directed the district court to reconsider the reasonable-royalty models it previously excluded because they included value-to-Ford components. On contract damages, the court reinstated the $82.26 million jury award because the record contained a reasonable evidentiary path based on annual license figures and the 7.5-year damages period. On Ford’s cross-appeal, the court rejected a heightened requirement that Versata prove Ford knew the specific elements of each combination trade secret; the evidence supported liability under the DTSA and MUTSA. damages remand standing / jurisdiction precedential damages remand standing / jurisdiction precedential damages remand precedential