Aspect Systems, Inc. v. Lam Research Corp.

MEMORANDUM

Lam Research Corporation (“Lam”) appeals from the judgment entered in favor of Aspect Systems, Inc. (“Aspect”) following a trial by jury. Aspect cross-appeals contending that the district court erred in awarding Lam prejudgment interest on Aspect’s unpaid amounts for the purchase of inventory. We affirm in part the judgment of the district court in favor of Aspect, and vacate and remand that portion of the judgment awarding prejudgment interest in favor of Lam.

I

In 2002, Aspect and Lam entered into an agreement wherein Lam would be “willing to sell certain assets and provide certain licenses under Lam’s patents, copyrights, trade secrets and know-how” to Aspect for “manufacturing], refurbishing], servicing and repairing] of AutoEtch and Drytek machines.”

Although the contract specifically stated that Aspect was acquiring all the assets in Exhibit A, it is undisputed that no such exhibit was attached to the 2002 agreement. After the parties entered into the agreement, Aspect complained to Lam that it failed to deliver certain parts, and that certain parts were obsolete and unusable. On June 25, 2004, due to Aspect’s complaints, the parties agreed to amend the 2002…