The Federal Circuit subsequently affirmed the district court's decision to overturn the willfulness verdict, holding that Pulse had presented evidence at trial that its belief in the invalidity of the patents was reasonable and not objectively reckless.

[2] Writing for a unanimous court, Chief Justice John Roberts issued an opinion reversing the Federal Circuit and overruling the Seagate test.

The Court held that this broad standard was incompatible with the narrow, specific requirement of the Seagate test that the infringer have acted in an "objectively reckless" manner.

The Court also criticized the Seagate test as requiring "clear and convincing evidence" of willfulness given that this heightened standard of proof did not appear in the text of Section 284.

Rather, in Justice Breyer's view, willful infringement would require both knowledge of the patent and some additional evidence of egregious conduct by the defendant.

[5] On September 6, 2017, the district court again denied Halo's request for enhanced damages, determining that there was insufficient evidence to prove that Pulse had acted in an egregious manner or like a "pirate.