“Section 285 of the Patent Act authorizes a district court to award attorney’s fees in patent litigation. It provides, in its entirety, that ‘[t]he court in exceptional cases may award reasonable attorney fees to the prevailing party.’ 35 U.S.C. § 285. In Brooks Furniture Mfg., Inc. v. Dutailier Int’l, Inc., 393 F.3d 1378 (2005), the United States Court of Appeals for the Federal Circuit held that ‘[a] case may be deemed exceptional’ under § 285 only in two limited circumstances: ‘when there has been some material inappropriate conduct,’ or when the litigation is both ‘brought in subjective bad faith’ and ‘objectively baseless.’ The question before us is whether the Brooks Furniture framework is consistent with the statutory text.”
“We hold that it is not. . . . The framework established by the Federal Circuit in Brooks Furniture is unduly rigid, and it impermissibly encumbers the statutory grant of discretion to district courts.”
