IANAL, but it seems like it shows that the plaintiff won... so they can say they found the other party culpable... but for $1. I'm guessing if the case was tossed out of court, even with prejudice, it likely would have been appealed or re-filed, so this helps ensure it has no real grounds for appeal?
At least WD is thinking about encryption. FDE is a critical thing these days, although I trust software FDE (LUKS, ZFS) more than I do hardware.
I doubt this can't be appealed. It's more do to with the fact that they couldn't show they suffered any damages (harm) from the infringement:
He cited [PDF] precedents where an award of damages was deemed unnecessary if the plaintiff could not "adequately tie a dollar amount" to the infringing acts.
"Accordingly, the Court enters nominal damages in the amount of $1," he stated.
For this reason, the portion of WD's Rule 59 Motion regarding damages was declared moot, while the request for a new trial was denied.
Despite the judge denying almost all of the storage firm's post-trial motions, its legal representatives Gibson Dunn claimed the reduction of damages "a significant win."
[...]
He cited [PDF] precedents where an award of damages was deemed unnecessary if the plaintiff could not "adequately tie a dollar amount" to the infringing acts.
"Accordingly, the Court enters nominal damages in the amount of $1," he stated.
For this reason, the portion of WD's Rule 59 Motion regarding damages was declared moot, while the request for a new trial was denied.
Despite the judge denying almost all of the storage firm's post-trial motions, its legal representatives Gibson Dunn claimed the reduction of damages "a significant win."
"Prior to trial, Western Digital made a successful motion to exclude SPEX's damages expert. SPEX then tried the case and attempted to put on a damages case without a damages expert. Based on damages theories that were never disclosed, and legally improper, the jury awarded SPEX over $250 million in damages," Gibson Dunn claimed in a statement sent to The Register.
So WD did infringe, but I guess because they were just a patent troll with no actual business they couldn't actually show they suffered any damages.
Not sure why they couldn't claim lost licensing revenue, maybe the rule was really made to combat patent trolls and it worked as intended?