The U.S. Court of Appeals for the Federal Circuit issued a nonprecedential decision January 23, 2026, in the patent infringement dispute between Orange Electronic Co. Ltd. and Autel Intelligent Technology Corp., Ltd. The case, docketed as 2024-1876 and 2024-1885, involved cross-appeals from both parties following a complex trial in the Eastern District of Texas.
Orange Electronic sued Autel in the Eastern District of Texas, alleging infringement of claims 26 and 27 of U.S. Patent No. 8,031,064. The case was heard before Judge J. Rodney Gilstrap, who presided over the proceedings that culminated in a jury trial and subsequent post-trial motions.
The jury reached several key findings in Orange Electronic's favor. The jury determined that both claims 26 and 27 of the '064 patent were not invalid as obvious under 35 U.S.C. § 103, rejecting Autel's obviousness defense. Additionally, the jury found that the patent claims were not directed to patent ineligible subject matter under 35 U.S.C. § 101, addressing concerns about patentability of the underlying invention. Most significantly for Orange Electronic, the jury concluded that Autel directly infringed the patent claims in question.
Following the jury verdict, Autel filed motions for judgment as a matter of law on three grounds: obviousness, patent ineligible subject matter, and noninfringement. These post-trial motions challenged the jury's findings and sought to overturn the verdict despite the jury's conclusions.
The district court's handling of these motions produced mixed results for both parties. Judge Gilstrap denied Autel's JMOL motions with respect to obviousness and patent ineligible subject matter, allowing the jury's findings on these issues to stand. The court determined that sufficient evidence supported the jury's conclusion that the patent claims were neither obvious nor directed to ineligible subject matter.
However, the district court granted Autel's motion for judgment as a matter of law on the issue of noninfringement. Despite the jury's finding that Autel had directly infringed the patent claims, Judge Gilstrap concluded that the evidence was insufficient to support this verdict. This ruling effectively overturned the jury's infringement finding and denied Orange Electronic the victory it had achieved at trial.
The conflicting rulings at the district court level set the stage for the Federal Circuit appeals. Orange Electronic, as the plaintiff-appellant, challenged the district court's grant of JMOL on noninfringement, seeking to restore the jury's infringement verdict. Meanwhile, Autel, as the defendant-cross-appellant, appealed the district court's denial of its JMOL motions on obviousness and patent ineligible subject matter.
The case was argued before a three-judge panel consisting of Circuit Judges Dyk, Taranto, and Cunningham, with Judge Dyk writing the opinion. John F. Rabena of Sughrue Mion, PLLC, argued for Orange Electronic, with additional representation by William Mandir. Nicole A. Saharsky of Mayer Brown, LLP, argued for Autel, supported by a team of attorneys including Clark Bakewell, James A. Fussell III, Gary Hnath, Bryan Nese, and Minh Nguyen-Dang, as well as Hao Tan and Shen Wang from Arch & Lake LLP in Chicago.
The Federal Circuit's decision was designated as nonprecedential, meaning it will not serve as binding precedent for future cases but resolves the specific dispute between these parties. Nonprecedential decisions are common in patent appeals where the resolution turns on case-specific facts rather than novel legal principles.
The case highlights the complex interplay between jury verdicts and judicial oversight in patent litigation. While juries determine factual questions such as infringement and invalidity, district courts retain the authority to grant judgment as a matter of law when they conclude that reasonable minds could not differ on the evidence presented.
The Eastern District of Texas, where the case originated, remains a popular venue for patent litigation due to its experienced judges and relatively expedited case management. Judge Gilstrap, who presided over the trial, is among the most experienced patent judges in the country, regularly handling complex intellectual property disputes.
The outcome of this Federal Circuit appeal will determine whether Orange Electronic can recover damages for patent infringement or whether Autel successfully defended against the infringement claims. The decision also addresses important questions about patent validity that could influence future litigation involving similar technology.
Both Orange Electronic and Autel appear to be technology companies, though the specific nature of their business relationship and the technology covered by the '064 patent are not detailed in the available court documents. The dispute represents the type of intellectual property conflict common in today's technology sector, where companies must navigate complex patent landscapes while developing competitive products.