Attorneys’ Fees Award for Plaintiff’s Inadequate Pre-Suit Infringement Investigation Affirmed Even Though Trial Court Never Reached Merits of Infringement

May 3, 2019

Reading Time : 3 min

In 2013, ThermoLife International, LLC (“ThermoLife”) brought a patent infringement suit against two dietary supplement manufacturers, Hi-Tech Pharmaceuticals, Inc. (“Hi-Tech”) and Vital Pharmaceuticals, Inc. (“Vital”). ThermoLife accused Hi-Tech and Vital of infringing four patents related to methods and chemical compositions for improving vascular function and physical performance. The district court bifurcated infringement and invalidity, holding first the bench trial on invalidity. At the bench trial, the district court held all four patents invalid for anticipation or obviousness, removing the need for a further trial on infringement.  

Hi-Tech and Vital then filed a motion for attorneys’ fees, arguing that the case was “exceptional” under 35 U.S.C. § 285 because ThermoLife’s presuit infringement investigation was inadequate as to one of the claims of the four asserted patents. The district court agreed and awarded $1.3 million in attorneys’ fees to Hi-Tech and Vital. 

ThermoLife appealed the award of attorneys’ fees on multiple grounds, all of which the Federal Circuit rejected. First, ThermoLife argued that the district court’s “exceptional case” determination was flawed because it was based on infringement issues and infringement was not fully litigated. The Federal Circuit acknowledged that, while it was “unusual” to base an award of attorneys’ fees on issues that were not actually litigated before the court, it was not erroneous to do so as long as due process and other procedural rights were respected in deciding the question. Here, ThermoLife did not point to any way in which its due process or procedural rights were violated.

ThermoLife further argued that it did not have sufficient notice that the defendants considered the infringement allegations baseless. The Federal Circuit held, however, that early notice, while important in many exception case analyses, is not a rigid prerequisite to obtaining attorneys’ fees—it is merely one factor the district can consider in deciding whether to make an award. In this case, it made sense to avoid retroactive imposition of a notice requirement because all parties to the litigation, including several defendants not present in the appeal, agreed to a bifurcated schedule that gave priority to the validity issues.  

The Federal Circuit further held that the district court did not err in determining that ThermoLife’s presuit investigation was inadequate for lack of testing. Whether presuit testing of an accused product is required depends on the circumstances of the particular case, including “the availability of the products at issue, the existence and costs of testing, and whether other sufficiently reliable information exists.” Here, there was undisputed evidence that the accused dietary supplements were readily available and that “simple tests” were available to determine how much of a claimed amino acid was present in the accused supplements. Further, although there was some evidence that ThermoLife relied on product advertising and labeling in its presuit infringement analysis, ThermoLife itself criticized the accuracy of the labels and advertisements. Thus, the Federal Circuit concluded, it was not erroneous for the district court to find that ThermoLife’s failure to test the accused products was unreasonable.

Finally, ThermoLife challenged four additional findings made by the district court in support of its conclusion that ThermoLife engaged in a “pattern of action” that supported its exceptional case determination. Specifically, the district court found that (i) ThermoLife was only a very small participant in the market, (ii) ThermoLife brought the suit just a few months before three of the patents were set to expire, (iii) ThermoLife brought many suits and (iv) most of the suits settled for “seemingly small amounts.” The Federal Circuit held that these facts alone would not be sufficient to show misconduct sufficient to support an exceptional case finding, and stressed that low settlement amounts could be the result of various legitimate considerations. Nevertheless, because ThermoLife’s presuit investigation was so inadequate, the Federal Circuit held that the district court’s consideration of additional factors did not undermine the ultimate determination that it was an exceptional case.

Practice Tip: A complete and thorough presuit investigation should be performed for all accused products before a suit is filed. This may include product testing when the product is publicly available and testing is the only reliable means by which infringement can be determined. 

ThermoLife Int’l LLC v. GNC Corp., Nos. 2018-1657, 2018-1666, slip op. (Fed. Cir. May 1, 2019).

Share This Insight

Previous Entries

IP Newsflash

March 24, 2025

The Federal Circuit affirmed a Patent Trial and Appeal Board (PTAB) final written decision holding that the prior art exception of AIA Section 102(b)(2)(B) does not apply to a prior sale by an inventor when the sale is conducted in private. According to the Federal Circuit, a sale must disclose the relevant aspects of the invention to the public to qualify for the prior art exception of Section 102(b)(2)(B).

...

Read More

IP Newsflash

March 21, 2025

Under the Lanham Act, a plaintiff who prevails on a trademark infringement claim may be entitled to recover the “defendant’s profits” as damages. The Supreme Court in Dewberry Group, Inc. v. Dewberry Engineers Inc. unanimously construed “defendant’s profits” in 35 USC § 1117(a) to mean that only the named defendant’s profits can be awarded, not the profits of other related corporate entities. The Court, however, left open the possibility that other language in § 1117(a) may allow for damages linked to the profits of related entities, if properly raised and supported.

...

Read More

IP Newsflash

March 13, 2025

In a series of rulings on a motion in limine, the District of Delaware recently distinguished between what qualifies as being incorporated by reference and what does not for the purposes of an anticipation defense. In short, a parenthetical citation was held to be insufficient, while three passages discussing a cited reference met the test.

...

Read More

IP Newsflash

March 4, 2025

On February 28, 2025, the USPTO announced that it was rescinding former Director Vidal’s 2022 memorandum on discretionary denials by the Patent Trial and Appeal Board. The 2022 memorandum effectively narrowed the application of discretionary denials in cases with parallel district court litigation by specifying instances where discretionary denial could not be issued. With the withdrawal of the memorandum, individual PTAB panels will regain flexibility in weighing discretionary denials. While the long-term effect of that increased flexibility is not yet known, the immediate effect is likely to be a shift towards the discretionary analysis applied by PTAB panels before the issuance of the memorandum.

...

Read More

IP Newsflash

March 3, 2025

A District of Delaware judge recently granted a defendant’s motion to include a patent prosecution bar in its proposed protective order after determining that litigation counsel’s ability to practice before the Patent Office—without ever having represented the plaintiffs at the Patent Office in the past—weighed heavily in favor of the bar.

...

Read More

IP Newsflash

February 12, 2025

The Federal Circuit recently reversed a district court decision that found a patent that did not describe after-arising technology failed to satisfy the written description requirement. In so doing, the Federal Circuit explained that written description and enablement are evaluated based on the subject matter that is claimed, not the products that practice those claims. As a result, the patentee was not required to describe unclaimed, later-discovered features of the accused products despite the broad language in the claims that undisputedly covered the products.

...

Read More

IP Newsflash

January 24, 2025

The District of Delaware recently rejected a patentee’s argument that non-production of an opinion letter from counsel, combined with knowledge of the patent, warranted a finding that defendant induced infringement.

...

Read More

IP Newsflash

January 17, 2025

The District of Delaware recently denied a motion to dismiss a patent infringement complaint involving gene editing technology that sought relief under the Safe Harbor Provision of the Hatch-Waxman Act. Specifically, the court found the patentee’s complaint sufficiently alleged at least some uses of the claimed technology that, when taken as true, were not solely uses of a “patented invention” that were “reasonably related” to an FDA submission.

...

Read More

© 2025 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. Attorney advertising. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. Prior results do not guarantee a similar outcome. Akin is the practicing name of Akin Gump LLP, a New York limited liability partnership authorized and regulated by the Solicitors Regulation Authority under number 267321. A list of the partners is available for inspection at Eighth Floor, Ten Bishops Square, London E1 6EG. For more information about Akin Gump LLP, Akin Gump Strauss Hauer & Feld LLP and other associated entities under which the Akin Gump network operates worldwide, please see our Legal Notices page.