Willis Electric v. Polygroup — Full Federal Circuit Declines to Disturb $71M Christmas Tree Patent Verdict

Background

Willis Electric, a maker of holiday lighting products, holds U.S. Patent No. 8,454,186, which covers a modular pre-lit artificial Christmas tree with trunk electrical connectors. The patented “One Plug” or “Quick Set” design allows tree sections to connect both mechanically and electrically in a single motion at any rotational orientation — eliminating the need to manually plug in separate electrical cords after assembling the trunk.

Willis sued Polygroup, a competing holiday products manufacturer, in the District of Minnesota in 2015. After Polygroup filed 16 inter partes review petitions at the PTAB — resulting in several claims being found unpatentable — Willis narrowed its case to a single surviving dependent claim (Claim 15, covering coaxial trunk connectors). A jury found the claim infringed and not invalid, awarding $42.5 million in damages based on a roughly $4-per-tree reasonable royalty. With interest, the total judgment grew to $71.4 million.

The Court’s Holding

In its February 17, 2026 panel opinion, the Federal Circuit affirmed the district court across the board. Writing for the panel, Chief Judge Moore rejected Polygroup’s challenges on both obviousness and damages.

On obviousness, the court found substantial evidence supported the jury’s verdict. Polygroup had argued Claim 15 would have been obvious by combining a prior art “Loomis GKI Tree” with standard coaxial barrel connectors, but the jury was entitled to credit Willis’s evidence of non-obviousness.

On damages, the court upheld all three components of expert Michele Riley’s reasonable royalty analysis: (1) an income-based apportionment analyzing profit premiums between Willis’s and Polygroup’s trees; (2) a market-based apportionment using comparable licenses, where the court held that “perfect identity between the licenses and asserted patents is not required”; and (3) a qualitative application of the Georgia-Pacific factors. The court distinguished its 2025 en banc EcoFactor decision, noting that testimony based on “factually inaccurate premises” is excludable, but methodological choices where “reasonable minds can differ” are properly left to the jury.

On May 18, 2026, the full Federal Circuit denied Polygroup’s petition for en banc rehearing without issuing any dissenting opinions.

Key Takeaways

• Damages methodology survives Daubert scrutiny when based on sound economic principles. The court reaffirmed that a multi-method reasonable royalty approach — combining income, market, and Georgia-Pacific analyses — is permissible even when the underlying data is imperfect, so long as the expert applies “sound economic principles” rather than factually inaccurate premises.
• EcoFactor’s reach has limits. The en banc denial signals the full Federal Circuit is comfortable with the panel’s line-drawing between excludable testimony (based on wrong facts) and admissible testimony (based on reasonable methodological choices). This gives damages experts meaningful latitude.
• IPR victories do not automatically reduce district court damages. Polygroup argued that the PTAB’s invalidation of the independent claim (Claim 10) should constrain damages on the surviving dependent claim (Claim 15). The court rejected this, noting that IPR uses “broadest reasonable interpretation” while district courts use the Phillips standard — different proceedings, different standards.

Why It Matters

The en banc denial solidifies one of the largest recent patent damages awards and provides important guidance on the post-EcoFactor landscape for patent damages experts. Companies defending against large damages claims should note that the Federal Circuit is drawing the Daubert line at factual accuracy, not methodological precision — an expert who uses reasonable but debatable analytical methods will generally survive exclusion.

The case also illustrates the durability of well-constructed patent claims. Despite 16 IPR petitions and years of validity challenges, a single dependent claim survived and supported a nine-figure judgment — a reminder that strategic claim drafting and prosecution can pay dividends even against aggressive challengers.