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IP News

By Jeffrey S. Ginsberg and Benjamin H. Weissman

Federal Circuit: Halo Electronics Sent Back to District Court

On Aug. 5, 2016, a Federal Circuit panel of Judges Lourie, O'Malley, and Hughes issued a unanimous decision, authored by Judge Lourie, in Halo Electronics, Inc. v. Pulse Electronics, Inc., Case Nos. 2013-1472, 2013-1656. The case was on remand from the Supreme Court after its June 13, 2016 decision, which held that the Federal Circuit erred in applying the “unduly rigid” test for enhanced damages under the framework in In re Seagate Technology, LLC, 497 F.3d 1360 (Fed. Cir. 2007) (en banc). The Federal Circuit, following the Supreme Court's guidance, vacated the district court's original ruling declining to enhance damages, reasoning that that decision was made under the now-abandoned Seagate test.

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