United States Court of Appeals for the Federal Circuit ______________________

MICHAEL PHILIP KAUFMAN, Plaintiff-Cross-Appellant

v.

MICROSOFT CORPORATION, Defendant-Appellant ______________________

2021-1634, 2021-1691 ______________________

Appeals from the United States District Court for the Southern District of New York in No. 1:16-cv-02880-AKH, Judge Alvin K. Hellerstein. ______________________

Decided: May 20, 2022 ______________________

RONALD ABRAMSON, ALEX G. PATCHEN, Liston Abram- son LLP, New York, NY, argued for plaintiff-cross-appel- lant. Also represented by ARI JASON JAFFESS.

CHRISTINA JORDAN MCCULLOUGH, Perkins Coie LLP, Seattle, WA, argued for defendant-appellant. Also repre- sented by DAN L. BAGATELL, Hanover, NH; TARA LAUREN KURTIS, Chicago, IL; AHMED JAMAL DAVIS, LEAH A. EDELMAN, Fish & Richardson P.C., Washington, DC; JOHN STEPHEN GOETZ, EXCYLYN HARDIN-SMITH, New York, NY; JASON W. WOLFF, San Diego, CA. ______________________ Case: 21-1634 Document: 45 Page: 2 Filed: 05/20/2022

2 KAUFMAN v. MICROSOFT CORPORATION

Before DYK, REYNA, and TARANTO, Circuit Judges. TARANTO, Circuit Judge. Michael Philip Kaufman owns now-expired U.S. Patent No. 7,885,981, on which he is a co-inventor. The patent describes and claims methods for using a computer to au- tomatically generate an end-user interface for working with the data in a relational database. Mr. Kaufman brought the present action against Microsoft Corporation, asserting infringement of claims of the patent by Mi- crosoft’s making and selling of its Dynamic Data product. A jury found Microsoft liable and awarded damages of $7 million to Mr. Kaufman. The district court upheld the ver- dict against Microsoft’s post-judgment challenges, Kauf- man v. Microsoft Corp., No. 1:16-cv-02880, 2021 WL 242672, at *1 (S.D.N.Y. Jan. 25, 2021) (JMOL Order), and it also denied Mr. Kaufman’s motion to amend the judg- ment to include prejudgment interest, Kaufman v. Mi- crosoft Corp., No. 1:16-cv-02880, 2021 WL 260485, at *1 (S.D.N.Y. Jan. 25, 2021) (Prejudgment Interest Order). Microsoft and Mr. Kaufman both appeal. We reject Mi- crosoft’s challenges and thus affirm the denial of Mi- crosoft’s post-judgment motions. But we agree with Mr. Kaufman’s challenges and reverse the denial of prejudg- ment interest. I A The ’981 patent addresses the creation of user inter- faces that permit users to interact with data in relational databases, which store data in multiple tables that are re- lated to each other in defined ways. For a particular data- base, such an interface should permit the user to view and manipulate the data according to the structure of the tables and their relationships—i.e., the “data model” or “schema” of the database. See ’981 patent, col. 2, lines 29–52. The Case: 21-1634 Document: 45 Page: 3 Filed: 05/20/2022

KAUFMAN v. MICROSOFT CORPORATION 3

specification notes that in the prior art, the database soft- ware itself and the user interface were typically developed separately, and significant manual programming was needed to create an interface that matched the data model built into the database software. Id., col. 2, line 53, through col. 3, line 4. An object of the invention, the patent indi- cates, is to enable a developer to create “a complete and fully functional user interface (UI) for any arbitrarily com- plex or large database schema, without any custom soft- ware programming.” Id., col. 3, lines 8–11. Claim 1 of the ’981 patent is representative for pur- poses of the issues before us. It recites: 1.