In the context of a district court litigation, a U.S. patent must be valid and enforceable or any potential reward for the Patent Owner will be moot. Defendants may argue that a patent is unenforceable in light of inequitable conduct committed during prosecution of the underlying patent application, but the standard to meet the requisite inequitable conduct to warrant unenforceability is supposedly higher after Therasense, Inc. v. Becton, Dickinson & Co., 649 F.3d 1276, 1290 (Fed. Cir. 2011) (en banc) (“This court now tightens the standards for finding both intent and materiality in order to redirect a doctrine that has been overused to the detriment of the public.”).