On June 13, 2016, the Supreme Court issued its opinion in Halo v. Pulse, overturning the Federal Circuit’s long-standing two-step test for willfulness and enhanced damages in patent-infringement cases. The Court’s ruling changes the patent infringement-damage landscape in three important ways. First, district courts can now award enhanced damages for willful infringement under 35 U.S.C. § 284 at their discretion, without applying the Federal Circuit’s rigid Seagate framework. Second, enhanced damages are now governed by a preponderance of the evidence standard, not the clear and convincing evidence standard that had previously applied. And third, enhanced damages are now reviewed on appeal for abuse of discretion. Halo lowers the burden on proof for enhanced damages, and infringement and invalidity opinions of counsel will likely be revived as essential tools in guarding against enhanced damages liability—as was the case pre-Seagate...