On Tuesday, the Federal Circuit denied cross-appeals from SSL Services LLC and Citrix Systems Inc. in a dispute that arose over patent claims to a virtual private network. SSL Services, LLC v. Citrix Systems, Inc., Fed. Cir No. 2013-1419, -1420, 10/14/2014. The outcome maintained SSL’s $15 million damages award against Citrix.
The Federal Circuit held that SSL prevailed for the purposes of attorney’s fees, rejecting a decision by the district court that found “both parties achieved some success and sustained some failure.” The decision followed the standard articulated in Farrar v. Hobby, 506 US 103(1992), that one qualifies as a prevailing party only when “actual relief on the merits of [a] claim materially alters the legal relationship between the parties… in a way that directly benefits the [party].” Id.