In Willis Electric Co. v. Polygroup Ltd., the Federal Circuit affirmed the denial of judgment as a matter of law on obviousness and denial for a new trial on damages in a dispute over pre‑lit Christmas trees.  The Federal Circuit upheld the district court’s decision that substantial evidence supported the jury’s finding that a skilled artisan would not have been motivated to modify the prior‑art tree to use coaxial connectors as claimed.  It also upheld the district court’s decision to not grant Polygroup’s motion for a new trial, arguing that the testimony from the patentee’s damages expert had fatal flaws.  The Federal Circuit left intact a roughly $42.5 million reasonable royalty award awarded by the district court.