December 17, 2025, 02:15 PM 
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“The doctrine of equivalents must be applied to individual elements of the claim, not to the invention as a whole.” – Federal Circuit
The U.S. Court of Appeals for the Federal Circuit (CAFC) on Wednesday issued a mixed, split, precedential ruling in Wonderland Switzerland AG v. Evenflo Company, Inc., reversing a permanent injunction and granting a new trial for willful patent infringement in a case between two child car seat manufacturers. The court found a district court judge abused his discretion both in granting an injunction based on speculative harm and in excluding a key email chain that asked how to “ingeniously” avoid a patent. The opinion was authored by Chief Judge Moore and Judge Reyna concurred-in-part and dissented-in-part.
Wonderland Switzerland AG filed a patent infringement suit in the U.S. District Court for the District of Delaware, alleging that Evenflo Company, Inc. infringed U.S. Patent Nos. 7,625,043 and 8,141,951. The ‘043 patent covers a car seat with a detachable seat back that includes a locking mechanism for selectively connecting the seat back to the seat assembly. The ‘951 patent is directed to a child safety seat with an adjustable backrest that includes an engaging mechanism with a tooth-shaped structure. Wonderland accused infringement on five of Evenflo’s convertible car seat models, including the EveryFit, EveryKid, SafeMax, Evolve, and Transitions models.
Following a trial in the district court, a jury determined that Evenflo’s 3-in-1 and 4-in-1 seats infringed claim 1 of the ‘043 patent under the doctrine of equivalents (DOE), and that various models also infringed claims of the ‘951 patent. However, the jury concluded that Evenflo’s infringement of the ‘043 patent was not willful. The district court subsequently granted Wonderland’s motion for a permanent injunction and denied post-trial motions from both companies, leading to the cross-appeals.
On appeal, Chief Judge Moore reversed the jury’s finding that Evenflo’s 4-in-1 seats infringed the ‘043 patent. The court determined there was no substantial evidence to support the verdict because the patent claim requires the seat back itself to have a “locking mechanism for selectively detachably connecting” it to the seat assembly. In Evenflo’s products, the components that perform the selective detachment, such as a handle and spring-loaded hooks, are located on the seat assembly, not the seat back. The court explained that the “[DOE] must be applied to individual elements of the claim, not to the invention as a whole,” and found no equivalence as a matter of law. This reversal also led the court to vacate the corresponding damages award.
For the ‘951 patent, the court found the injunction was an abuse of discretion because Wonderland had expressly stated it was not seeking one. In the ‘043 patent, the court concluded the district court improperly relied on “speculative and conclusory evidence” of irreparable harm. Wonderland had argued that it suffered lost sales and reputational damage through its exclusive supplier, Graco Children’s Products Inc., but the Federal Circuit found no concrete evidence tying Graco’s alleged lost market share directly to Evenflo’s infringement, as opposed to the many other competitors in the market. The court was particularly critical of testimony from a Wonderland managing director who speculated that a lost car seat sale “naturally leads” to lost sales of other products, calling such testimony insufficient to establish irreparable harm.
In its cross-appeal, Wonderland successfully argued that the district court erred by denying it a new trial on willful infringement of the ‘043 patent. The Federal Circuit agreed that the district court abused its discretion when it excluded an email chain between an employee of Evenflo’s affiliate, Goodbaby Child Products Co., Ltd., and Evenflo employees. In the email, the Goodbaby employee noted that one of Evenflo’s accused products, the Evenflo Evolve, might fall within the scope of the ‘043 patent’s claims and asked how to “avoid the claims of the patent ingeniously.”
The Federal Circuit found this email highly probative of willfulness, which requires showing “deliberate or intentional infringement,” not merely knowledge of the patent. The court reasoned that the email went beyond mere awareness and demonstrated that Evenflo was on notice of a specific infringement risk and that its affiliate was actively seeking ways to design around the patent. The majority rejected the district court’s concerns about unfair prejudice and jury confusion, stating that any risks could have been managed through redactions or limiting instructions. The exclusion was not harmless, the court concluded, because it impaired Wonderland’s right to prove its willfulness case. The court therefore reversed the denial of a new trial and remanded the case for a new trial on willful infringement of the ’043 patent, but only as it relates to the 3-in-1 seats.
Circuit Judge Reyna dissented from the majority’s decision on the willfulness issue. In his view, the district court’s decision to exclude the email chain was not “arbitrary and irrational” and deserved deference. Judge Reyna argued that the email primarily concerned a non-accused product, the “Dracula” car seat, and that introducing it would have been confusing and prejudicial to Evenflo. He contended that the majority had improperly substituted its own judgment for that of the trial judge.
Ultimately, the Federal Circuit affirmed the district court’s judgment on all other issues, including several claim construction rulings. However, the court reversed the infringement finding for the 4-in-1 seats, vacated the damages award, reversed the permanent injunction in its entirety, and remanded for a new trial on willfulness for the 3-in-1 seats.
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