Octane Fitness, LLC v. ICON Health & Fitness, Inc.

Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U.S. 545 (2014),^[1] is one of two U.S. Supreme Court decisions issued on April 29, 2014 regarding patent lawsuit fee-shifting (the other case being Highmark v. Allcare Health).^[2] The Supreme Court essentially made it easier for courts to make the loser pay for all attorney costs if the lawsuit is regarded as frivolous. In other words, "the Supreme Court's decision grants judges more leeway to crack down on baseless claims."^[3]

Octane Fitness, LLC v. ICON Health & Fitness, Inc.
Supreme Court of the United States
Argued February 26, 2014 Decided April 29, 2014
Full case name	Octane Fitness, LLC, Petitioner v. ICON Health & Fitness, Inc.
Docket no.	12-1184
Citations	572 U.S. 545 (more) 134 S. Ct. 1749; 188 L. Ed. 2d 816; 2014 U.S. LEXIS 3107; 82 U.S.L.W. 4330; 110 U.S.P.Q.2d 1337
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	Icon Health & Fitness, Inc. v. Octane Fitness, LLC, No. 0:09-cv-00319, 2011 WL 3900975 (D. Minn. Sept. 6, 2011); affirmed, 496 F. App'x 57 (Fed. Cir. 2012); cert. granted, 134 S.Ct. 49 (2013)
Court membership
Chief Justice John Roberts Associate Justices Antonin Scalia · Anthony Kennedy Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan
Case opinion
Majority	Sotomayor, joined by Roberts, Kennedy, Thomas, Ginsburg, Breyer, Alito, Kagan; Scalia (except footnotes 1–3)

The decision is particularly relevant for the so-called patent trolls, which "will have to add a new variable to their calculations before pursuing a marginal lawsuit over their intellectual property: the other side's legal fees."^[4] The decision was unanimous, with the opinion written by Justice Sonia Sotomayor.^[4]

Background

In the underlying litigation, ICON Health & Fitness, the manufacturer of such brands as NordicTrack and ProForm, sued Octane Fitness, a relatively small and specialized maker of elliptical trainers, for patent infringement. Octane Fitness, arguing that their elliptical products did not infringe ICON's patent, won on summary judgment and later moved for reimbursement for their attorney's fees. The district court denied the motion for attorney's fees, stating that even though Octane Fitness eventually prevailed, ICON's claims were not objectively baseless,^[1]: 5–6 but the Supreme Court reversed this decision.

See also

• Fogerty v. Fantasy, Inc. (1994): awarding attorney's fees in a copyright case
• Peter v. NantKwest, Inc. (2019): awarding attorney's fees in a patent case
• List of United States Supreme Court cases, volume 572