Copyright Infringement

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7^th Circuit Court of Appeals

Case Name: Motorola Solutions, Inc. v. Hytera Communications Corporation Ltd.

Case No.: 22-2413

Officials: Hamilton, Brennan, and St. Eve, Circuit Judges.

Focus: Copyright Infringement

Motorola Solutions, Inc. and Hytera Communications Corporation Ltd. are both prominent competitors in the global market for two-way radio systems. Hytera, after facing challenges in developing its own competing products, recruited three engineers from Motorola. Before leaving Motorola, these engineers downloaded thousands of documents and files containing Motorola’s trade secrets and copyrighted source code. Utilizing this stolen material, Hytera introduced a line of radios that closely mirrored Motorola’s products. In response, Motorola sued alleging copyright infringement and misappropriation of trade secrets.

The jury determined that Hytera had indeed violated both the Defend Trade Secrets Act of 2016 (DTSA) and the Copyright Act. They awarded Motorola $764.6 million in compensatory and punitive damages. Subsequently, the district court reduced the total award to $543.7 million but denied Motorola’s request for a permanent injunction. Both parties appealed the district court’s rulings.

The Seventh Circuit ruled that the district court must recalculate the damages awarded under copyright law, which were initially set at $136.3 million. The appellate court affirmed the district court’s decision to award $135.8 million in compensatory damages and $271.6 million in punitive damages under the DTSA. Additionally, the Seventh Circuit determined that the district court erred in denying Motorola’s motion for reconsideration regarding the denial of a permanent injunction. Therefore, the case was remanded to the district court for further consideration of the permanent injunctive relief issue.

Affirmed in part, reversed in part and remanded.

Decided 07/02/24

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