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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

JENS H.S. NYGAARD,

Plaintiff,

v.

FÉDÉRATION INTERNATIONALE DE 

L’AUTOMOBILE, FORMULA ONE 

MANAGEMENT LTD., FORMULA ONE 

WORLD CHAMPIONSHIP, MERCEDES-BENZ 

GRAND PRIX LTD., DAIMLER AG, LEWIS 

HAMILTON, RED BULL TECHNOLOGY 

LTD., RED BULL RACING LTD., FERRARI 

S.P.A., CHARLES LECLERC, and DALLARA 

AUTOMOBILI S.P.A.,

Defendants.

Case No. 6:20-cv-00234-ADA

JURY TRIAL REQUESTED

ORDER

Before the Court is Plaintiff Jens Nygaard (“Plaintiff”) and defendants Red Bull 

Technology Ltd. and Red Bull Racing Ltd. (collectively “Red Bull”) Joint Motion To Enter 

Stipulation Regarding A Separate Trial. Having considered the motion, the Court finds that the 

motion should be GRANTED. The Court hereby ORDERS:

1. All of Nygaard’s claims against Red Bull and all of Red Bull’s defenses to 

Nygaard’s claims are severed for a separate pre-trial conference and a separate trial from all of 

Nygaard’s claims against defendants Fédération Internationale de l’Automobile (“FIA”), Formula 

One Management Ltd. and Formula One World Championship (collectively “F1”) and all of FIA’s 

and F1’s defenses to Nygaard’s claims. 

Case 6:20-cv-00234-ADA Document 299 Filed 04/20/22 Page 1 of 3
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2. The separate pre-trial conference and trial between Nygaard and Red Bull will 

occur after a final judgment or dismissal is filed that resolves all of Nygaard’s claims against FIA 

and F1 after the separate trial among Nygaard and FIA and F1. 

3. Nygaard and Red Bull will agree upon a separate schedule for the exchange and

submission of pre-trial disclosures, motions in limine, and their pre-trial order in advance of the 

separate pre-trial conference for the separate trial between Nygaard and Red Bull. 

4. Red Bull will not be bound or precluded by any “FIA/F1 Findings” defined as: 

any rulings, orders, opinions, decisions, conclusions, findings, verdicts and judgments by the Court 

or the jury, and any arguments, statements, admissions and/or stipulations by Nygaard, FIA and/or 

F1, regarding any of Nygaard’s claims against FIA and/or F1 or any of FIA and/or F1’s defenses 

to Nygaard’s claims, whether made before, during or after the separate pre-trial conference or the 

separate trial among Nygaard and FIA and F1. By way of example only, Red Bull will not be 

bound or precluded by any FIA/F1 Finding that the accused Halo infringed any asserted claim of 

the ’178 patent, that any Formula One team including Red Bull Racing infringed any asserted 

claim of the ’178 patent, that any asserted claim of the ’178 patent is not invalid, or that Nygaard 

should recover damages from FIA or F1 for any infringement. 

5. Paragraph 4 above shall not apply to any FIA/F1 Finding for which Red Bull 

participated in the submissions to the Court that led to the FIA/F1 Finding by, for example, joining 

a joint motion or joint opposition filed by Red Bull, FIA and F1.

6. This stipulation shall have no effect on whether and, if so, to what extent Nygaard 

will or will not be bound or precluded by any FIA/F1 Findings, which will instead be determined 

in accordance with any applicable preclusion doctrines, including for example law of the case, 

issue preclusion, collateral estoppel, claim preclusion, res judicata, and judicial estoppel. 

Case 6:20-cv-00234-ADA Document 299 Filed 04/20/22 Page 2 of 3
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Signed this ____ day of April, 2022.

_________________________________

ALAN D. ALBRIGHT

UNITED STATES DISTRICT JUDGE

20th

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