By: Derek Hawkins//June 22, 2016//
US Supreme Court
Case Name: Halo Electronics, Inc. v. Pulse Electronics, Inc.
Case No.: 14-1513
Focus: Patent Infringement
The Seagate test is not consistent with 35 U.S.C. §284
“The pertinent language of §284 contains no explicit limit or condition on when enhanced damages are appropriate, and this Court has emphasized that the “word ‘may’ clearly connotes discretion.” Martin v. Franklin Capital Corp., 546 U. S. 132, 136. At the same time, however, “[d]iscretion is not whim.” Id., at 139. Although there is “no precise rule or formula” for awarding damages under §284, a district court’s “discretion should be exercised in light of the considerations” underlying the grant of that discretion. Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U. S. ___, ___. Here, 180 years of enhanced damage awards under the Patent Act establish that they are not to be meted out in a typical infringement case, but are instead designed as a sanction for egregious infringement behavior
Vacated and Remanded
Dissenting:
Concurring: BREYER, KENNEDY, ALITO