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Explore the latest in patent, trademark, and copyright cases on the Merchant & Gould LLP blog. Stay informed with expert insights on intellectual property law updates.

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Last week, the U.S. Court of Appeals for the Federal Circuit issued an opinion in <em>Wonderland Switzerland AG v. Evenflo Company, Inc.</em>, Nos. 2023-2043, -2233, -2326 (Dec. 17, 2025).

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Wonderland sued Evenflo, alleging five of Evenflo’s convertible car seat models infringed various claims of Wonderland’s ’043 and ’951 patents. At trial, the jury found (1) Evenflo’s 3-in-1 and 4-in-1 seats infringed claim 1 of the ’043 patent under the doctrine of equivalents (DOE), (2) Evenflo’s infringement of the ’043 patent was not willful, (3) the 4-in-1 seats infringed claims 1 and 5 of the ’951 patent, and (4) the 3-in-1 seats infringed claim 1 of the ’951 patent. The district court granted Wonderland’s motion for permanent injunctive relief (enjoining activities related to both patents even though Wonderland only moved on the ’043 patent) and denied the parties’ cross-motions for judgment as a matter of law and for a new trial. Evenflo appealed.

The Federal Circuit affirmed-in-part, reversed-in-part, vacated-in-part, and remanded. First, the Court reversed the DOE finding on claim 1 of the ’043 patent as to Evenflo’s 4‑in‑1 seats. The Court explained that the claims required the “locking mechanism for selectively detachably connecting” to be on the seat back, and that no substantial evidence showed the accused 4‑in‑1 seat backs contained any elements to satisfy this limitation literally or by equivalence. The Court otherwise rejected Evenflo’s claim construction challenges to the ’043 patent and held that substantial evidence supported the jury’s findings.

Second, the Court affirmed the findings of infringement of the ’951 patent, finding the district court correctly construed the disputed claim term (“connected”) and that substantial evidence supported the jury’s infringement finding.

Third, the Court vacated the permanent injunctions in full. As to the ’951 patent, the Court explained that Wonderland expressly did not seek injunctive relief, so granting it was an abuse of discretion. As to the ’043 patent, the Court concluded the record showed only speculative assertions about lost sales, market share, and reputational harm, and that such conjecture cannot establish irreparable injury under <em>eBay</em> and its progeny.

Finally, the Court ordered a new trial on willful infringement of the ’043 patent limited to the 3‑in‑1 seats. The Court held the district court abused its discretion by excluding highly probative emails showing awareness of infringement risk and efforts to “avoid the claims,” which were admissible for notice and manageable via redaction or instructions.

CAFC Trims Injunction, Orders New Willfulness Trial in Car Seat IP Battle

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