In Power Integrations, Inc. v. Fairchild Semiconductor Int’l, Inc., No. 2011-1218 (Fed. Cir. Mar. 26, 2013), the Federal Circuit vacated both the original jury damages and the district court’s remitted award because lost sales in foreign jurisdictions are not “infringement” under U.S. patent laws. The Federal Circuit held that the jury’s award of $33.9 million was contrary to law because it was based on worldwide sales. The patentee is not entitled to compensatory damages for injury caused by activity that occurred outside the territory of the United States. Evidence of one or more acts of direct infringement in the United States provide “neither compelling facts nor a reasonable justification for finding that Power Integrations is entitled to ‘full compensation’ in the form of damages based on loss of sales in foreign markets which it claims were a foreseeable result of infringing conduct in the United States.”