The Federal Circuit has affirmed a $3.2 million attorney-fee award in Carnegie v. Fenix Diamonds, ruling that the patent owner's claims were objectively baseless. The decision rests on a standard that Octane Fitness left as sufficient but not required for such awards.
The court's holding clarifies that a showing of objective baselessness alone can support a fee award, even if the full Octane framework is not satisfied. This gives district courts a clearer, though narrower, route to sanctioning meritless litigation.
While Octane set a flexible, totality-of-circumstances test, this case demonstrates that a specific finding of objective baselessness can tip the balance decisively. The outcome underscores the practical weight of that showing in fee-shifting disputes.