By Matthew Becker ( January 25, 2018, 1:57 PM EST) -- In Exmark Manufacturing Company v. Briggs & Stratton Power, the U.S. Court of Appeals for the Federal Circuit approved a reasonable royalty damages theory based on the total value of an accused product, even though the patented invention was only part of a multicomponent product.[1] Exmark is remarkable. The Federal Circuit did not mention the entire market value rule and approved of apportioning the royalty rate, instead of a royalty base, to separate the damages attributable to the patented invention from non-patented features. Exmark continues a trend of the Federal Circuit departing from the vigorous application of the entire market value and seemingly unambiguous statements in its earlier Uniloc[2] and LaserDynamics[3] decisions prohibiting apportionment of the royalty rate....