The objective of this paper is to develop a methodology to better understand behavioral empathy in the design process for the purpose of addressing user needs. To accomplish this, content analysis was conducted on undergraduate student assignments that documented group projects designing a consumer product. Using qualitative data analysis, the assignments and presentations were coded for their levels of behavioral empathy, using a scale that applied psychology and design theories. The Interpersonal Reactivity Index was administered to the students to assess their trait empathy. Results from these two analyses showed little connection between levels of behavioral empathy and self-assessed trait empathy of the student groups. The student assignments did reveal empathic waves that demonstrated comprehension and application of expressed user needs, evidenced by ascending and descending the empathy scale. These results indicate that is it not trait empathy that leads to empathic design, but rather applied empathy in the design process; developing internal empathy is not sufficient if it does not effectively translate user needs to technical requirements in the final design.