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Door-Master Corp. v. Yorktowne, Inc.

In patent infringement case, denial of defendant's motion for judgment as a matter of law affirmed because jury's factual findings of infringement were supported by substantial evidence; denial of plaintiff's request for attorneys' fees affirmed because court's findings were neither in conflict with jury's nor clearly erroneous.

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After a jury trial, the United States District Court for the District of New Jersey awarded Door-Master Corporation damages for Yorktowne, Inc.’s and Conestoga Wood Specialties, Inc.’s infringement of U.S. Patent No. Des. 338,718 (the ’718 patent). The district court denied Yorktowne’s and Conestoga’s motion for judgment as a matter of law. The district court also declined to award attorney fees to Door- Master even though the jury found that Yorktowne’s infringement was willful. Because the district court did not err in denying judgment as a matter of law and did not abuse its discretion in declining to award attorney fees, this court affirms.

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There are two basic ways to mount a cabinet door on the surrounding cabinet frame: inset mounting and overlay mounting. With inset mounting, the door fits within the frame and does not cover any of the frame’s front surface. The front surface of an inset-mounted door is typically flush with the front surface of the surrounding frame. With overlay mounting, the door covers some or all of the frame’s front surface. The rear surface of an overlay-mounted door abuts the front surface of the frame and the front surface of the door is offset from the front surface of the frame. During mounting, inset-mounted doors are more difficult to align with the surrounding frame, but they generally have a more desirable appearance than overlay-mounted doors.

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