Nearly three years ago, in Halo Electronics Inc. v. Pulse Electronics Inc.,[1] the U.S. Supreme Court altered the ground rules on willfulness in patent infringement litigation. Halo eased a patentee’s burden to demonstrate willful infringement by eliminating the requirement to show objective recklessness and putting the focus on the accused infringer’s subjective beliefs. This article explores how willfulness has been playing out in the district courts since Halo.