Opticurrent, LLC v. Power Integrations, Inc.
- Edward Chen
- 3:17-cv-03597
- U.S. District Court · Northern District of California
- 2
Opticurrent v. Power Integrations: Judge Chen granted Power Integrations’ motion to pause enforcement of the judgment while its appeal proceeds.
Power Integrations, Inc. received a stay of execution of the judgment; Opticurrent, LLC’s ability to enforce and collect the judgment was paused during the specified appeal, with the bond providing security.
What happened
In Opticurrent, LLC v. Power Integrations, Inc., Power Integrations asked the court to pause enforcement of the judgment while it appealed the court’s order denying its motion for a new trial under Rule 60. It provided a bond to protect Opticurrent if the judgment were upheld.
The court explained that a party generally has the right to pause enforcement after posting a sufficient bond. Power Integrations’ bond totaled $1,943,105.86, covering 125% of Opticurrent’s award and later royalties. The court rejected Opticurrent’s argument that Fifth Circuit law should apply, holding that the stay question was governed by federal procedural law and Ninth Circuit precedent.
Judge Edward Chen granted Power Integrations’ motion and stayed enforcement of the judgment until the appeal of the Rule 60 motion is decided. The order disposed of Docket No. 384.
The detailed version
- Opticurrent, LLC v. Power Integrations, Inc. · No. 3:17-cv-03597
- Edward Chen
- Apr. 6, 2021
Background
Power Integrations, Inc. moved to stay execution of the judgment against it while it appealed the court’s order denying its motion for a new trial under Federal Rule of Civil Procedure 60. The motion was Docket No. 384.
Federal Rule of Civil Procedure 62(b) permits a party to obtain a stay after judgment by providing a bond or other security. A supersedeas bond protects the party that won the judgment—in this case, Opticurrent, LLC—by ensuring that the judgment and interest can be collected if the judgment is affirmed on appeal.
Bond and Applicable Law
Power Integrations obtained a supersedeas bond equal to 125% of Opticurrent’s $1,199,987 award, plus 125% of subsequent royalties. The total bond amount was $1,943,105.86, and the bond stated that it was provided pending the appeal from the Rule 60 order. The court found the bond sufficient to protect Opticurrent from loss during the stay.
Opticurrent argued that the court should deny the stay under a Fifth Circuit decision because the case had been transferred under 28 U.S.C. § 1404 from the Eastern District of Texas. The court rejected that argument. It held that staying execution of a judgment pending appeal is a federal-law question, not a state-law question, and that Ninth Circuit law therefore governed the motion.
Ruling
Judge Edward Chen granted Power Integrations’ motion to stay execution of the judgment until its appeal of the Rule 60 motion is decided. The order disposed of Docket No. 384.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.