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SECTION 285

Highmark, Inc. v. Allcare Health Management Systems, Inc.

Issues

Is a district court’s finding that a patent suit is objectively baseless entitled to deference?

Respondent Allcare Health Management Systems, Inc., owns U.S. Patent No. 5,301,105, which covers a method of data entry and management used in the context of medical treatment. In 2002, Allcare notified Petitioner Highmark, Inc., a medical insurance provider, that Highmark was infringing on Allcare’s patent. Highmark sought a declaratory judgment of noninfringement; Allcare counterclaimed for infringement. After the district court granted summary judgment in Highmark’s favor, Highmark moved for an award under 35 U.S.C. § 285, which grants attorneys’ fees for “exceptional cases.” Though the district court granted the award for two of Allcare’s claims, the Federal Circuit Court of Appeals reviewed the claims de novo and reversed one of them. The Supreme Court granted certiorari to determine the scope of deference given to district courts to find “exceptional cases.” The ruling in this case, in tandem with another case before the Court, Octane Fitness, LLC v. Icon Health & Fitness, Inc., will impact how long and how readily litigants may pursue future patent cases.

Questions as Framed for the Court by the Parties

Whether a district court's exceptional-case finding under 35 U.S.C. § 285, based on its judgment that a suit is objectively baseless, is entitled to deference.

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Facts

Respondent Allcare Health Management Systems, Inc. (“Allcare”) owns U.S. Patent No. 5,301,105 (“the ’105 patent”), which covers a health management system that facilitates interactions among physicians, patients, employers, banks, and insurance companies. See Highmark, Inc. v. Allcare Health Mgmt.

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Hill v. McDonough

Issues

Is a district court’s finding that a patent suit is objectively baseless entitled to deference?

 

Respondent Allcare Health Management Systems, Inc., owns U.S. Patent No. 5,301,105, which covers a method of data entry and management used in the context of medical treatment. In 2002, Allcare notified Petitioner Highmark, Inc., a medical insurance provider, that Highmark was infringing on Allcare’s patent. Highmark sought a declaratory judgment of noninfringement; Allcare counterclaimed for infringement. After the district court granted summary judgment in Highmark’s favor, Highmark moved for an award under 35 U.S.C. § 285, which grants attorneys’ fees for “exceptional cases.” Though the district court granted the award for two of Allcare’s claims, the Federal Circuit Court of Appeals reviewed the claims de novo and reversed one of them. The Supreme Court granted certiorari to determine the scope of deference given to district courts to find “exceptional cases.” The ruling in this case, in tandem with another case before the Court, Octane Fitness, LLC v. Icon Health & Fitness, Inc., will impact how long and how readily litigants may pursue future patent cases.

Questions as Framed for the Court by the Parties

Whether a district court's exceptional-case finding under 35 U.S.C. § 285, based on its judgment that a suit is objectively baseless, is entitled to deference.

Respondent Allcare Health Management Systems, Inc. (“Allcare”) owns U.S. Patent No. 5,301,105 (“the ’105 patent”), which covers a health management system that facilitates interactions among physicians, patients, employers, banks, and insurance companies. See Highmark, Inc.

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Edited by

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