Halo Electronics v. Pulse Electronics

In Halo Electronics v. Pulse Electronics, 579 U.S. 93, 110 (2016), the U.S. Supreme Court made it easier to obtain increased damages for willful infringement of a patent. This is one of the few patent decisions by the Supreme Court favoring inventors, and opens the door to larger damage awards in patent cases.

The Case

Both companies supply electronics. Halo once tried to license their patents to Pulse in 2002, but failed, and in 2007, sued Pulse for infringement. The court tried to prove that the infringement was done willfully, objectively and subjectively, could not prove it done objectively and thus lost. Justice Stephen G. Breyer declared that Section 284 states that damages paid can equal up to only 3 times that damage done, on which Anthony Kennedy and Samuel Alito agreed.

The Opinion

Specifically, the U.S. Supreme Court overruled the Seagate test for enhanced damages (up to three times the proven damages) for willful patent infringement:

“

Section 284 gives district courts the discretion to award enhanced damages against those guilty of patent infringement. In applying this discretion, district courts are “to be guided by [the] sound legal principles” developed over nearly two centuries of application and interpretation of the Patent Act. Martin, 546 U.S., at 139, 126 S. Ct. 704, 163 L. Ed. 2d 547 (internal quotation marks omitted). Those principles channel the exercise of discretion, limiting the award of enhanced damages to egregious cases of misconduct beyond typical infringement. The Seagate test, in contrast, unduly confines the ability of district courts to exercise the discretion conferred on them. Because both cases before us were decided under the Seagate framework, we vacate the judgments of the Federal Circuit and remand the cases for proceedings consistent with this opinion.

”

579 U.S. at 110.

External links

• Official Court Document