Mealey's (December 6, 2019, 10:27 AM EST) -- WASHINGTON, D.C. — A California federal judge erred in denying a patent owner a jury trial on the calculation of a release payment based upon retrospective “fair, reasonable and non-discriminatory” (FRAND) rates for past unlicensed sales by appellees, the Federal Circuit U.S. Court of Appeals ruled Dec. 4 (TCL Communication Technology Holdings Ltd., et al. v. Ericsson Inc., et al., Nos. 2018-1363, -1732, Fed. Cir., 2019 U.S. App. LEXIS 36090)....