Chaffin v. Braden was decided on June 23, 2017 on appeal from the Southern District of Texas. There, the district court granted defendant Braden’s motion for summary judgment of non-infringement, adopting Braden’s claim construction. The court subsequently found the case exceptional and awarded attorney fees to Braden. Chaffin appealed.
The Federal Circuit reversed the district court’s grant of summary judgment of non-infringement and vacated the award of attorney fees.
Under §285, the court may only award attorney fees “to the prevailing party.” A prevailing party is one that has “received at least some relief on the merits.” Because the Federal Circuit reversed the grant of summary judgment and remanded, Branden was no longer the prevailing party. The Federal Circuit thus vacated the award of attorney fees.
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Chaffin v. Braden, 696 F. App’x 1001 (Fed. Cir. 2017)