Brooks Furniture Manufacturing, Inc.: Case Study

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Section 285 of the Patent Act authorizes district courts to award attorney’s fees to the winning parties in cases deemed “exceptional.” In Brooks Furniture Manufacturing Inc. v Dutailier International Inc. the Federal Circuit Court defined an “exceptional” case as one that either involves “material inappropriate conduct” cite or one that is both “objectively baseless” and “brought in subjective bad faith.” cite
However, in April of 2014 the Supreme Court held that the framework set forth in Brooks Furniture was “unduly rigid and [that it] impermissibly encumbered the statutory grant of discretion to the District Courts” in Octane Fitness. cite The precedent set from Octane Fitness was such that a case could be exceptional if it “stands out from others with respect to the substantive strength of a party’s litigating position… or the unreasonable manner in which the case was litigated”. cite The court also established that the District Courts determine whether a case is “exceptional” in a case-by-case manner wherein the consideration of the “totality of [the] circumstances” is required. cite Lastly, the Supreme Court decision in Octane Fitness discarded the requirement of “clear and convincing” cite evidence in favor of a …show more content…

The amount of District Court opinions ruling a case exceptional and granting attorney fees has increased by a significant margin in the years since Octane Fitness. cite https://www.law360.com/articles/777116/notable-trends-in-post-octane-fitness-fee-awards With the loosening of the requirements to make a case “exceptional” a larger variety of situations can be classified as such. For example, even a failure to fully investigate the alleged reasoning for a plaintiff’s entitlement for damages could lead to the case being classified as “exceptional.”

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