The Southern District of New York, in Adrea, LLC v. Barnes & Noble, Inc., et al., 13 Civ. 4137 (Judge Rakoff) (February 24, 2016), ordered a new trial on damages. At trial, the jury found that Defendants infringed two of the three asserted patents, and awarded Plaintiff $1.33 million in lump sum, compensatory damages. After trial, the Court found that one of the two patents was invalid. Since the jury did not allocate its damages award between the two patents, the Court requested letter briefing from the parties on how to allocate the damages award and whether a new trial on damages was necessary. (slip op. at 1 – 2).