Halo Elec,, Inc. v. Pulse Elec., Inc., No. 13-1472 (Fed. Cir. 2016)
Annotate this CaseHalo owns patents directed to surface mount electronic packages containing transformers for mounting on a printed circuit board inside electronic devices. Halo alleged infringement by Pulse. The district court entered summary judgment that Pulse did not sell or offer to sell accused products within the U.S. and, therefore, did not directly infringe, and that Pulse’s infringement with respect to accused products sold and delivered outside the U.S. was not willful. The Federal Circuit affirmed, upholding the constructions of the claim limitations “electronic surface mount package” and “contour element,” finding the patents not invalid for obviousness, and affirming the judgment of direct infringement with respect to products delivered in the U.S. and the judgment of inducement with respect to products delivered outside the U.S. but ultimately imported by others. The Supreme Court granted Halo’s certiorari petition with respect to enhanced damages, and held that Section 284 of the Patent Act “gives district courts the discretion to award enhanced damages . . . in egregious cases of misconduct beyond typical infringement.” On remand, the Federal Circuit left undisturbed the judgments on other issues, but vacated its unenhanced damages award with respect to products that were delivered in the United States, and remanded for further proceedings consistent with the Supreme Court’s opinion.
This opinion or order relates to an opinion or order originally issued on October 22, 2014.
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