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

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Octane Fitness, LLC v. ICON Health & Fitness, Inc.
Argued February 26, 2014
Decided April 29, 2014
Full case nameOctane Fitness, LLC, Petitioner v. ICON Health & Fitness, Inc.
Docket no.12-1184
Citations572 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
ArgumentOral argument
Opinion announcementOpinion announcement
Case history
PriorIcon 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
MajoritySotomayor, joined by Roberts, Kennedy, Thomas, Ginsburg, Breyer, Alito, Kagan; Scalia (except footnotes 1–3)

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]

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]


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[edit]


  1. ^ a b Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U.S. 545 (2014).
  2. ^ Highmark Inc. v. Allcare Health Mgmt. Sys., Inc., 572 U.S. 559 (2014).
  3. ^ Robertson, Adi (April 29, 2014). "Supreme Court decision makes it easier to stick patent trolls with court costs". The Verge. Retrieved May 4, 2014.
  4. ^ a b Fisher, Daniel (April 29, 2014). "Patent Trolls Face Higher Risks As Supreme Court Loosens Fee-Shifting Rule". Forbes. Retrieved May 4, 2014.

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