On June 13, the US Supreme Court handed down an important unanimous decision relaxing the standard for an award of enhanced patent damages under 35 U.S.C. § 284. See Halo Electronics, Inc. v. Pulse Electronics, Inc., 579 U.S. ___ (June 13, 2016) (hereinafter cited as "Slip Op. at ___"). The Court eliminated the "rigid" Federal Circuit test that was previously used and replaced it with a more flexible standard that gives district courts broad discretion to award enhanced damages in "egregious cases of misconduct beyond typical infringement." Slip Op. at 15. The Court re-focused the § 284 analysis on the subjective intent of the alleged infringer at the time of infringement and eliminated the showing of "objective recklessness" as formerly required by the Federal Circuit.