U.S. District Judge Amos Mazzant of Sherman recently hammered Samsung with $21 million in enhanced damages, making him the first jurist in the Eastern District of Texas to triple an award against a patent defendant for willful infringement under a new U.S. Supreme Court standard.

In June, the U.S. Supreme Court in Halo Electronics v. Pulse Electronics loosened the standard in which defendants can be assessed enhanced damages for egregious willful infringement. That ruling gave trial court judges more discretion to increase damages for egregious willful infringement under 35 U.S.C. § 284, dropping a clear and convincing standard that was previously imposed on them.