St. Luke's Hospital Ass'n v. United States

“exemplary damages [under patent act] and attorneys’ fees are not money claims triable by jury, although they are awarded in a legal action.” | jury request upheld in patent infringement action where plaintiff requested, inter alia, an accounting for profits and damages | jury trial; trial of damage issue in patent cases is “often difficult and expensive” yet “easily severed” from liability questions; additional opportunity for avoiding or settling damage issue created by separation; nonmovants failed to show “serious prejudice” in separation | bifurcating patent case into liability and damage trials