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As Chief Justice John Roberts wrote in the Halo decision, "Awards of enhanced damages under the Patent Act over the past 180 years establish that they are not to be meted out in a typical infringement case, but are instead designed as a punitive or vindictive sanction for egregious infringement behavior. An analysis of lower court decisions after the Halo decision found that Although not required, district courts commonly consider the factors the Federal Circuit laid out in Read Corp

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These vary in the strength and consistency of supporting evidence, so it is useful to distinguish between the better-established findings and those representing a more preliminary evidence base