Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

damagesstatutewillpatentcorporationtreble damages
damagesstatutewillpatentcorporation

Related Cases

Lam, Inc. v. Johns-Manville Corp., 718 F.2d 1056, 219 U.S.P.Q. 670
View Case »
Braun Inc. v. Dynamics Corp. of America, 975 F.2d 815, 61 USLW 2204, 24 U.S.P.Q.2d 1121
View Case »
Beatrice Foods Co. v. New England Printing and Lithographing Co., 923 F.2d 1576, 59 USLW 2480, 17 U.S.P.Q.2d 1553
View Case »
Mercoid Corp. v. Minneapolis-Honeywell Regulator Co., 320 U.S. 680, 64 S.Ct. 278, 88 L.Ed. 396, 60 U.S.P.Q. 30
View Case »
Beatrice Foods Co. v. New England Printing and Lithographing Co., 923 F.2d 1576, 59 USLW 2480, 17 U.S.P.Q.2d 1553
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Halo Electronics, Inc. v. Pulse Electronics, Inc., 579 U.S. 93, 136 S.Ct. 1923, 195 L.Ed.2d 278, 84 USLW 4386, 118 U.S.P.Q.2d 1761, 16 Cal. Daily Op. Serv. 6086, 2016 Daily Journal D.A.R. 5663, 26 Fla. L. Weekly Fed. S 246

Facts

In the first action, Halo Electronics, Inc. accused Pulse Electronics, Inc. of infringing its patents related to electronic surface-mount packages. The district court ruled that Pulse did not directly infringe Halo's patents and that the patents were not invalid for obviousness. In a second action, Stryker Corporation sued Zimmer, Inc. for infringing patents on pulsed lavage devices, resulting in a jury finding of willful infringement. The district court awarded treble damages, but the Federal Circuit later vacated this award, leading to certiorari granted in both cases.

In the first action, Halo sent Pulse two letters offering to license Halo's patents. After one of its engineers concluded that Halo's patents were invalid, Pulse continued to sell the allegedly infringing products. In 2007, Halo sued Pulse. The jury found that Pulse had infringed Halo's patents, and that there was a high probability it had done so willfully.

Issue

Whether the Federal Circuit's two-part test for enhanced damages under the Patent Act is consistent with the governing statute.

Whether the Federal Circuit's two-part test for enhanced damages under the Patent Act is consistent with the governing statute.

Rule

Analysis

Conclusion

The Supreme Court vacated the Federal Circuit's decisions and remanded the cases, holding that the Seagate test for enhanced damages was inconsistent with the Patent Act.

Who won?

The Supreme Court ruled in favor of the patentees, Halo Electronics and Stryker Corporation, by rejecting the Federal Circuit's two-part test for enhanced damages.

You must be