After a jury trial finding American Technical Ceramics Corp. ("ATC) willfully infringed Presidio Component's ("Presidio") patent, ATC filed a motion for a finding of no willful infringement based on the Supreme Court's decision in Halo. At the time the jury reached its verdict, the Federal Circuit's decision in In re Seagate Tech required that "an award of enhanced damages [under section 284] requires a showing of willful infringement." In re Seagate Tech., LLC, 497 F.3d 1360, 1368 (Fed. Cir. 2007) (en banc).
ATC argued that in light of the Supreme Court's decision in Halo, the jury's verdict as to willfulness is void and should be disregard. The district court explained that on June 13, 2016, the Supreme Court issued its decision in Halo Elecs., Inc. v. Pulse Elecs., Inc., No. 14-1513, 579 U.S. __ (June 13, 2016). In Halo, the Supreme Court rejected the Federal Circuit's two-part test from Seagate for determining when a district court may award enhanced damages as inconsistent with § 284. Id., slip op. at 1-2. The Supreme Court explained that § 284 commits the award of enhanced damages to the discretion of the district court. See id. at 8, 12-13, 15. The Supreme Court further explained that the Seagate test is "'unduly rigid'" and "'impermissibly encumbers'" a district court's discretion, particularly its requirement that there must be a finding of objective recklessness in every case before a district court may award enhanced damages.