Three-Sentence Legal Conclusion Insufficient For Finding Case Exceptional

The U.S. Court of Appeals for the Federal Circuit issued a soft, but distinct, reprimand to a lower court, for failing in its duty to provide sufficient "reasoning for its determination that a case is exceptional" that the appellate court can "provide meaningful review." The Federal Circuit also expounded on how a district court should conduct an "exceptional case" analysis when claim meaning is disputed. Innovation Technologies, Inc. v. Splash! Medical Devices, LLC., Case No. 06-CV-0647 (Fed. Cir., June 16, 2008) (Friedman, J.).

Innovation Technologies owns a patent relating to a method of irrigating wounds and sued a competitor, Splash! Medical Devices for infringement. Over a year later, Innovation "(1) executed a covenant not to sue Splash for infringement of the patent by the Splash device involved in [the] case and (2) moved to dismiss its suit with prejudice." The district court granted the