Victor Deng and Dm Technology & Energy, Inc. v. Clarence “buddy” Scroggins and Complete Lighting Source, Inc.

Summary

The court affirmed the judgment on the breach-of-contract claim because that portion of the judgment was not challenged on appeal. It held that the fraud claim was not preempted by federal patent law because inventorship was relevant but not essential to proving the alleged fraudulent promise. The court nevertheless reversed the fraud judgment and ordered a new trial because the compensatory-damages award rested on speculative evidence, requiring vacation of the related punitive-damages award.