The U.S. Court of Appeals for the Federal Circuit has held that post-judgment interest on a $20 million punitive damages award should be calculated from the date of the district court’s amended judgment after appeal and not from its original judgment in Tronzo v. Biomet, Case No. 01-1585 (Feb. 12, 2003).
The plaintiff sued Biomet, Inc. for patent infringement, fraud and breach of confidential relationship. In 1996, a jury awarded the plaintiff almost $4 million in compensatory damages, which the district court enhanced by almost $2 million based on the jury finding of willful infringement. The plaintiff was also awarded punitive damages of $20 million. On appeal, the Federal Circuit ruled that the plaintiff's patent was invalid and remanded for recomputation of compensatory damages on the tort claims. On remand, the district court reduced the compensatory damages as instructed, despite the fact that the award of punitive damages was never appealed. The district court also reduced the
