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Judgment As a Matter of Law Improper in Amazon 1-Click Case

By Robyn Hagan Cain on September 26, 2011 | Last updated on March 21, 2019

Internet impulse shoppers, rejoice! Your Amazon 1-Click is safe — barring further judicial intervention.

The Federal Circuit Court of Appeals ruled on Friday that Amazon, the world’s largest online retailer, did not violate Cordance Corporation’s patents with its 1-Click purchasing system.

Cordance Corporation, in an $84 million patent infringement lawsuit, claimed that Amazon’s 1-Click purchasing system and customer feedback procedures infringed on three of Cordance’s patents.

The Amazon 1-Click system allows customers to store payment information and shipping addresses in their Amazon customer accounts; the information can then be retrieved later when that customer uses the 1-Click feature. The customer feedback feature allows customers to enter reviews of products for sale on Amazon's website, and to enter reviews of transactions with third-party sellers. Cordance holds patents on similar systems, and Amazon holds a patent for 1-Click purchasing.

At trial, a jury found that Amazon had not infringed on two of the patents, and that the third patent was invalid. The district court overturned the invalidity judgment. Both parties appealed.

The Federal Circuit Court of Appeals found that the district court judge had erred in reversing the jury's invalidity finding and entering a judgment as a matter of law.

The court noted that a general jury verdict of invalidity should be upheld if there was sufficient evidence to support any of the alternative theories of invalidity. "A failure of proof with respect to any single item of evidence does not justify a grant of either judgment as a matter of law or a new trial; even if some of the proposed factual grounds ... are not generally sufficient to support a verdict, that is not fatal, because the critical question is whether the evidence, taken as a whole, was sufficient to support the jury's verdict."

In the absence of any ruling on the sufficiency of the evidence on both theories presented to the jury on the contested patent claim, the district court had no basis to find the jury's general verdict unsustainable on the written description theory alone. Thus, the Federal Circuit Court of Appeals found that the judgment as a matter of law ruling on the written description was improper.

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