Octane Fitness, LLC. v. ICON Health & Fitness, Inc.
April 29, 2014
Case #: 12-1184
Sotomayor, J., delivered the opinion of the Court, in which Roberts, C.J., and Kennedy, Thomas, Ginsburg, Breyer, Alito, and Kagan, JJ., joined, and in which Scalia, J., joined except as to footnotes 1-3.
Full Text Opinion: http://www.supremecourt.gov/opinions/13pdf/12-1184_gdhl.pdf
Patents: The Brooks Furniture framework is unduly rigid and inconsistent with the statutory text of 35 U.S.C. § 285.
Petitioner and Respondent are exercise equipment manufacturers. Respondent owned the '710 patent and sued Petitioner for infringement based on two of Petitioner's exercise machines.
The district court granted Petitioner's motion for summary judgment, but denied Petitioner's motion for attorney's fees under the Brooks Furniture test, finding no evidence that litigation was objectively baseless or brought in objective bad faith. The Federal Circuit upheld the denial of attorney's fees, refusing to consider what may be considered "exceptional," so as to allow for attorney's fees.
The Supreme Court reversed the Federal Circuit and remanded the case for further proceedings, holding that Brooks Furniture framework is not consistent with the statutory text of 35 U.S.C. § 285.
The reasoning for reversing this case is that the Brooks Furniture framework is too rigid and encumbers the discretion of the district courts impermissibly. Furthermore, the Court rejected the Brooks Furniture framework because it is too demanding; effectively rendering § 285 superfluous. Finally, the Court reversed because the Brooks Furniture framework applied in this case called for a standard of "clear and convincing evidence" in order to grant attorney's fees. However, there is no basis in the statute for such a high level of proof.