Halo Electronics Inc. v. Pulse Electronics Inc.
Holding
Section 284 of the Patent Act provides that, in a case of infringement, courts "may increase the damages up to three times the amount found or assessed." Under the Federal Circuit's two-part Seagate test, damages may be increased under Section 284 only if the patent owner can show, by clear and convincing evidence, both that "the infringer acted despite an objectively high likelihood that its actions constituted infringement of a valid patent" and that the risk of infringement "was either known or so obvious that it should have been known to the accused infringer." The Seagate test is "unduly rigid" and not consistent with the text of Section 284.
Judgment
Vacated and remanded, 8-0, in an opinion by John Roberts on Jun 13, 2016. Justice Breyer filed a concurring opinion, in which Justices Kennedy and Alito joined.
Recommended Citation: Halo Electronics Inc. v. Pulse Electronics Inc., SCOTUSblog, https://www.scotusblog.com/cases/halo-electronics-inc-v-pulse-electronics-inc/