A sample opening appeal brief that a patent owner may use as a starting point when challenging a patent damages judgment before the US Court of Appeals for the Federal Circuit. This brief addresses reasonable royalty and lost profits damages. It contains arguments by a patent owner to challenge any claim construction relied on to support the damages judgment, judgment as a matter of law (JMOL) determinations, evidentiary rulings, jury instructions, and summary judgment. This Standard Document contains integrated drafting notes with important explanations and tips.