A sample opening appeal brief that an accused infringer 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 an accused infringer to challenge claim construction, 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.