Law360, New York ( June 14, 2016, 5:45 PM EDT) -- In 2007, following years of criticism regarding a willful infringement standard that many believed was too lax, a unanimous en banc Federal Circuit established a new, more stringent standard for proving willful patent infringement. That decision[1] created the so-called "Seagate test" for proving willfulness. Now, in the case Halo Electronics Inc. v. Pulse Electronics Inc.,[2] a unanimous U.S. Supreme Court has rejected the Federal Circuit's Seagate test as inconsistent with the controlling statute, 35 U.S.C. § 284. The Supreme Court has instead given greater latitude to district court judges and juries to decide the willfulness question, and, accordingly, when a victorious patentee may be awarded enhanced damages, while still cautioning that such a finding should be made only in egregious cases....