In Texas Advanced Optoelectronic Solutions v. Renesas Electrics, a jury found Renesas liable for both patent infringement and trade secret misappropriation. The jury awarded a reasonable royalty for infringement and a disgorgement of profits for misappropriation. The Federal Circuit affirmed a jury finding that Renesas was liable for trade secret misappropriation and patent infringement for a set of apparatus claims, but vacated the damages awards in the case and remanded for further proceedings… There is no right for a jury to award a disgorgement of profits in trade secret misappropriation cases under the Seventh Amendment. Double recovery of damages for essentially same injury is not justified by presenting two legal theories for relief.