## Facts

- SCA Hygiene Products Aktiebolag owned a patent covering certain adult incontinence products.
- In 2003, SCA notified First Quality that First Quality’s products infringed SCA’s patent.
- First Quality responded that SCA’s patent was invalid in light of First Quality’s earlier patent.
- In 2004, SCA sought USPTO reexamination of its patent; in 2007, the USPTO confirmed the patent’s validity.
- SCA did not notify First Quality of the reexamination result and did not sue until 2010.
- The district court granted summary judgment for First Quality on laches and equitable estoppel, holding laches barred damages despite 35 U.S.C. § 286’s six-year look-back on recoverable damages.
- The Federal Circuit (panel and en banc) affirmed the availability of laches to bar damages within § 286’s six-year period.
- The Supreme Court granted review to decide whether laches can bar legal damages within § 286’s time limit.

## Issues

1. Whether laches may bar a patent infringement claim for legal damages incurred within the six-year period specified in 35 U.S.C. § 286.
2. Whether 35 U.S.C. § 282(b)’s reference to “unenforceability” preserves laches as a defense to legal damages notwithstanding § 286.

## Decision

- The Supreme Court held that laches cannot be invoked to bar claims for legal damages incurred within § 286’s six-year period.
- The Court vacated the Federal Circuit’s judgment in part and remanded for further proceedings.
- The Court left undisturbed the ruling on equitable estoppel.
- The Court stated that laches may still affect equitable relief, including injunctive relief, even though it cannot bar timely damages.

## Legal Principles

- When Congress has set a limitations rule for a legal remedy, courts may not use laches to shorten the period Congress prescribed.
- Section 286 reflects Congress’s judgment that a patentee may recover damages for infringement committed within six years before filing suit; laches cannot override that judgment as to legal damages.
- Laches historically functioned in equity and generally did not bar legal damages where a statute of limitations governed.
- Section 282(b)’s “unenforceability” defense does not clearly incorporate a laches bar to legal damages in a way that would displace § 286.
- Equitable doctrines (including equitable estoppel) remain available, and courts retain equitable discretion over prospective or equitable remedies.

## Conclusion

The Court ruled that laches cannot bar patent damages for infringement occurring within the six-year period set by 35 U.S.C. § 286, rejecting the Federal Circuit’s contrary rule while preserving equitable defenses and equitable limits on non-damages relief.


SCA Hygiene Prods. Aktiebolag v. First Quality Baby Prods., LLC, 137 S. Ct. 954 (2017)