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Octane Fitness, LLC v. ICON Health & Fitness, Inc.

United States Supreme Court
572 U.S. 545 (2014)


Facts

ICON Health & Fitness, Inc. (ICON) (plaintiff) and Octane Fitness, LLC (Octane) (defendant) were both manufacturers of exercise equipment. ICON brought suit against Octane, alleging that Octane manufactured exercise machines that violated ICON’s patents. The trial court granted Octane’s motion for summary judgment, concluding that Octane’s machines did not infringe ICON’s patent. Octane then moved for attorney’s fees under § 285 of the Patent Act. The trial court denied Octane’s motion. The court determined that Octane could show neither that ICON’s claim was objectively baseless, nor that ICON had brought it in subjective bad faith. The court also found no subjective bad faith on ICON’s part. ICON appealed the judgment of noninfringement, and Octane cross-appealed the denial of attorney’s fees. The Federal Circuit affirmed both orders. In upholding the denial of attorney’s fees, the Federal Circuit rejected Octane’s argument that the trial court had applied an overly restrictive standard in refusing to find the case exceptional under § 285. The Federal Circuit declined to revisit the standard for exceptionality. The Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Sotomayor, J.)

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