Halo Electronics, Inc. v. Pulse Electronics, Inc.
United States Supreme Court
136 S. Ct. 1923 (2016)
A jury found that Pulse Electronics (defendant) infringed several of Halo Electronics' (plaintiff) patents and that there was a high probability the infringement was willful. Under the Federal Circuit's Seagate framework, however, the trial court declined to award enhanced damages because Pulse had raised a defense that was not objectively baseless, meaning Halo could not show the objective recklessness Seagate required as a threshold matter; the Federal Circuit affirmed, and the Supreme Court consolidated the case with a similar dispute for review.
Whether the Seagate test's requirement that a patentee first prove objective recklessness by clear and convincing evidence, before a court may even consider enhanced damages, is consistent with § 284 of the Patent Act.