Apple won't be receiving any additional damages for willful infringement as it had hoped. However, it's important to remember that just because the willfulness has been overturned, the $1.049 billion infringement verdict itself hasn't. That said, Koh could in theory reduce the damages Samsung owes, though she has yet to offer any rulings to that effect at this time.
The willfulness finding followed a bevy of other rulings in connection with the case, with Judge Koh otherwise hewing closely to the jury's own findings — including a refusal to ramp up damages on several other grounds as Apple had requested. One exception was Samsung's '941 standards-essential patent, which covers wireless packet transmission.Judge Koh ruled that claims 10 and 15 of the patent were invalid — something the jury felt Apple hadn't proved. Since Apple wasn't found to have infringed on said patent claims in the first place, however, Koh's judgment has no immediate impact on this particular case.Source
The willfulness finding followed a bevy of other rulings in connection with the case, with Judge Koh otherwise hewing closely to the jury's own findings — including a refusal to ramp up damages on several other grounds as Apple had requested. One exception was Samsung's '941 standards-essential patent, which covers wireless packet transmission.Judge Koh ruled that claims 10 and 15 of the patent were invalid — something the jury felt Apple hadn't proved. Since Apple wasn't found to have infringed on said patent claims in the first place, however, Koh's judgment has no immediate impact on this particular case.Source