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The Courts Government Patents

A Federal Judge's Decision Could End Patent Trolling (computerworld.com) 168

"Forcing law firms to pay defendants' legal bills could undermine the business model of patent trolls," reports Computerworld. whoever57 writes: Patent trolls rely on the fact that they have no assets and, if they lose a case, they can fold the company that owned the patent and sued, thus avoiding paying any of the defendant's legal bills. However in a recent case, the judge told the winning defendant that it can claim its legal bills from the law firm. The decision is based on the plaintiff's law firm using a contract under which it would take a portion of any judgment, making it more than just counsel, but instead a partner with the plaintiff. This will likely result in law firms wanting to be paid up front, instead of offering a contingency-based fee.
The federal judge's decision "attacks the heart of the patent-troll system," according to the article, which adds that patent trolls are "the best evidence that pure evil exists."
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A Federal Judge's Decision Could End Patent Trolling

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  • Thanks EditorDave! (Score:5, Insightful)

    by Notabadguy ( 961343 ) on Sunday January 08, 2017 @12:36PM (#53628779)

    The recent rash of clickbait on Slashdot made me expect this headline to be, "Could a Federal Judge's Decision End Patent Trolling?"

    Thanks for not being a shitposting assclown. May your peers follow your example.

  • by mi ( 197448 ) <slashdot-2017q4@virtual-estates.net> on Sunday January 08, 2017 @12:40PM (#53628797) Homepage Journal

    patent trolls are "the best evidence that pure evil exists."

    Not to deny that abuse of the patent-system is wrong, but things like murdering a girl after raping her seem evil of considerably higher purity.

    • by klingens ( 147173 ) on Sunday January 08, 2017 @12:46PM (#53628829)

      I kinda disagree.
      A murdering rapist is a totally batshit crazy insane individual. So far off the reservation there is not even a planet in sight. No standard of behaviour can be expected from such a person. Probably cannot really comprehend what he's doing.

      A patent troll however is a totally sane and calculating individual according to any textbook. However he does his actions anyways. That is pure evil.

      Batshit crazy vs. pure evil.

      • Messed up morality (Score:2, Insightful)

        by sjbe ( 173966 )

        A patent troll however is a totally sane and calculating individual according to any textbook. However he does his actions anyways. That is pure evil.

        You seriously think patent trolls are as bad as genocide? Slavery? Premeditated murder? You need to sort out your priorities mate because if you really believe patent trolls are the worst of all evils then you have some seriously messed up notions about the world and ethics.

        • by MightyMartian ( 840721 ) on Sunday January 08, 2017 @01:02PM (#53628931) Journal

          How about trying to keep breast cancer tests as expensive as possible for personal profit?

          https://www.techdirt.com/artic... [techdirt.com]

          • by mi ( 197448 )

            How about trying to keep breast cancer tests as expensive as possible for personal profit?

            Everything you do at work, for example, is "for personal profit". Would fewer or more women die, if the profiteer you are denouncing did not exist — and, consequently, his test was not available at any cost?

            Messed up indeed...

            • by MightyMartian ( 840721 ) on Sunday January 08, 2017 @06:50PM (#53630437) Journal

              I think every member of a society should balance personal motives such as profit, against the greater good. Making a life-saving test extraordinarily expensive, and then pursuing anyone who develops a lower cost variant, particularly when the "test" as it were is simply identifying pre-existing and non-made-made genes, thus potentially harming thousands of people who the test's costs mean they cannot be tested cannot be justified save as a purely selfish and, dare I say it, sociopathic act. We should be doing all we can to get sociopaths out of any kind of corporate governance, not allowing them to game the system to our detriment and to their gain.

            • by silentcoder ( 1241496 ) on Monday January 09, 2017 @06:27AM (#53632331)

              >Everything you do at work, for example, is "for personal profit". Would fewer or more women die, if the profiteer you are denouncing did not exist — and, consequently, his test was not available at any cost?

              That scenario is impossible - and your claim is disproven by history. The correct counter-example is Jonas Salk. Created a vaccine that prevented one of the most debilitating diseases in human history (a disease which has killed at least one beloved US president by the way). Did not patent it. Did not even TRY to profit from it (was very happy with his middle-class professor's salary)... gave it to the world for free, and eradicated a disease entirely.

              And since myriad are not staffed by gods knowing forbidden knowledge - had they not existed other researchers WOULD without any doubt have discovered those genes too - and NOT tried to see how many women they could kill.

              You know what it's called when you tell somebody "give me a crapload of money or die ?" it's called robbery and extortion. It is definitely not called "doing honest business".

          • There's also those who work to prevent making the US price of AIDS drugs cheaper by making political agreements to manipulate the price [bit.ly].

        • Genocide and slavery are not perpetrated by single individuals. Hitler did not personally murder 6 million jews. He actually murdered no one. His staff did. Those numerous individuals send the commands onward.

          If a patent troll has a patent on a part of a drone and that drone kills a town on demand that in fact that trolls fault. The most a slaver could be guilty of is 144 the maximum that would fit in the hull of his frigate. I explained about murder already. Evil is on higher orders. The more people affect

      • by mi ( 197448 )

        A murdering rapist is a totally batshit crazy insane individual.

        Do you have statistics for the insanity defense being used in such cases? I'm afraid, it is not as common as you believe. Such criminals really are evil — not insane.

        And I can offer other examples, which a patent troll, however pissed off a judge may get at them, does not come close to matching...

        • by Dahamma ( 304068 )

          Yep, applying "insanity defense" for a criminal who does something radically against the mores (and morals) of a society is just as wrong as applying the insanity argument to someone making a technological breakthrough (luckily that's mostly left to history now) or in any way thinking radically differently from the general population. It's possible to disagree or just disregard societies' morals and laws and still be sane - that's basically one definition of a "criminal"...

          It sounds awful today, but histor

      • by Dahamma ( 304068 )

        A murdering rapist is a totally batshit crazy insane individual. So far off the reservation there is not even a planet in sight. No standard of behaviour can be expected from such a person. Probably cannot really comprehend what he's doing.

        Hearing stories about the atrocities of war involving these same activities - and worse, even though that's often hard to imagine - you'd either have to conclude (possibly hundreds of) thousands of soldiers were batshit crazy insane. Otherwise maybe being perfectly sane but bereft of morals (or having their societal moral compass stripped from them by training, indoctrination, or group mentality) is the much more likely option.

    • by Anonymous Coward on Sunday January 08, 2017 @12:48PM (#53628841)

      Hyperbole is the most heinous abomination against God that mankind has ever committed.

    • by Sebby ( 238625 )

      patent trolls are "the best evidence that pure evil exists."

      Not to deny that abuse of the patent-system is wrong, but things like murdering a girl after raping her seem evil of considerably higher purity.

      You're right. The fact that Wall Street execs have ruined the lives of millions and gotten away scot-free (and in fact, have gotten better off by getting 'bailed out') is better proof that "pure evil exists".

    • by MightyMartian ( 840721 ) on Sunday January 08, 2017 @01:02PM (#53628929) Journal

      I think each shows a kind of pure evil in its own way. Yes, as a matter of degrees some sociopath with a law degree who uses his intellect and education to fuck over entire industries isn't committing an act quite as evil as a psychopathic pedophile that rapes and murders a child.

      Or, maybe in some cases [techdirt.com] patent trolls and murderers same degree of evil.

    • I disagree. Why? A Rape/murder is an act of individual power and a show of hatred. However evil it is (and it is evil) it is still only a single individual.

      A patent troll could patent something that could effect a million lives or more, leading to those deaths if its in medical, power or weapon fields. Even if it is in Computer IT, these things are more intrusive everyday and can cause deaths on a massive scale if used in a particular narrow aspect. So a million small bad events does cause a cascade

    • Chaotic evil vs. Lawful evil

      Lawful evil is much greater evil because it is coldly calculated...

  • GREAT decision. (Score:2, Insightful)

    by Anonymous Coward

    It's logical, it's practical, it has no downsides I can imagine. Why can't we have more common sense judgment like this?

    • Here's a downside. (Score:5, Insightful)

      by Ungrounded Lightning ( 62228 ) on Sunday January 08, 2017 @01:51PM (#53629151) Journal

      it has no downsides I can imagine.

      If generalized beyond patent trolling suits it could severely limit the ability of shallow-pocket plaintiffs to obtain legal council on a contingency fee basis to obtain redress for the torts that damaged, and perhaps impoverished, them.

      The result would be that the legal system becomes accessible only to the rich.

      • it has no downsides I can imagine.

        If generalized beyond patent trolling suits it could severely limit the ability of shallow-pocket plaintiffs to obtain legal council on a contingency fee basis to obtain redress for the torts that damaged, and perhaps impoverished, them.

        The result would be that the legal system becomes accessible only to the rich.

        It is possible, but there is no reason to expect it to go there.

        The problem only arises because of an expansive view of corporations is allowing too many corporations that were designed to fail as part of their business model, thereby privatizing the gains and socializing the losses. These corporate entities are simply not businesses in the pedestrian manner of a restaurant or a tech start up. In a sense, the court is searching for a real person as a plaintiff, other than the fake person which is the corp

      • "If generalized beyond patent trolling suits it could severely limit the ability of shallow-pocket plaintiffs to obtain legal council on a contingency fee basis to obtain redress for the torts that damaged, and perhaps impoverished, them.

        The result would be that the legal system becomes accessible only to the rich."

        I'm not entirely sure about that.

        What it will do is force the lawfirms to be a lot more picky about what cases they pick up. They'll pretty much limit themselves only to those cases which have a

      • That's a fair point. But this doesn't get rid of contingency-based legal aid for legitimate cases. Lawyers aren't supposed to file frivolous cases but so far there has been no punishment if they do so. This is simply finding a way to enforce existing rules.
    • I don't think this will do as much as the author thinks to end patent trolls.

      The article did not specify, but I don't think the district of East Texas will take very kindly to this sort of ruling, as there is money to be made from the Law. Judge Rodney Gilstrap [vice.com]in particular might be a bit upset.

  • Exaggerate much? (Score:5, Insightful)

    by sjbe ( 173966 ) on Sunday January 08, 2017 @12:50PM (#53628849)

    according to the article, which adds that patent trolls are "the best evidence that pure evil exists."

    Really? That's a little hyperbolic don't you think? Yes patent trolls are a very bad thing but let's not exaggerate their impact or how much they matter. They certainly are not evil on the scale of slavery or war or genocide or any number of other horrific crimes. I'm tempted to make some snarky Trump joke since he is (not kidding) better evidence for pure evil than patent trolls but even that would be an unfair comparison given some of the real evils of the world.

    Patent trolls are extortionists and leeches on society and terrible human beings but the "best evidence that pure evil exists"? No. No they are not.

    • We've lowered the bar for "pure evil".

      Maybe they consider that other stuff adulterated evil.

    • Not an exaggeraion, IMHO. The impact of patent abuse is a lot worse than a few cases you hear about. It's the cases you DON'T hear about, where the mere threat of a bogus patent lawsuit is enough to suppress competition and prevent new products and services from reaching the market. This ruling in this case does not provide a universal solution to the problem, but it's a good start.

      • Re:Exaggerate much? (Score:5, Informative)

        by ShanghaiBill ( 739463 ) on Sunday January 08, 2017 @01:49PM (#53629137)

        Not an exaggeraion, IMHO.

        Yes, it is an exaggeration. I once met a Rwandan woman who, as a child, hid in a crawlspace while her mother was raped and then hacked to death with a machete. Her mother was one of 800,000 Rwandans who died that way. Dealing with an annoying patent lawsuit is not worse than genocidal mass murder.

        • Re: (Score:3, Insightful)

          by Anonymous Coward

          Uh huh. If we're really going to get pedantic about this stupid shit, then "pure evil" doesn't represent the magnitude of evil but rather how much it is diluted by other factors. Thus it is certainly possibly for a small scale evil to be just as pure as a large one.

          Also: the parent poster was talking about the economic impact of patent trolls, and while the harm which that sort of thing causes may not be as obvious as genocide it can potentially be just as severe. Drug patents kill people every day. How man

          • "pure evil" doesn't represent the magnitude of evil but rather how much it is diluted by other factors.

            By that measure, the evilness of NPEs (patent trolls) is not very "pure". NPEs help small independent inventors by enforcing many legitimate patents for real innovation. On balance, I think NPEs are harmful and need to be reined in, but they (occasionally) do some good.

      • by swb ( 14022 ) on Sunday January 08, 2017 @03:00PM (#53629437)

        My wife works in a business licensing IP and I hear some of the opposite side of the story. The nature of their product is such that it can't be made and distributed in any centralized way, so the business model is mostly licensing the product to producers who then participate in selling and marketing it locally under a common brand name.

        Anyway, they occasionally get knocked off by producers. Sometimes its licensees who keep making it after their agreement expires, sometimes its producers who outright knock it off, making their own tooling.

        They *could* sue all of them for patent infringement, but it's just not practical. In some cases the patent is close to expiration, in some cases its mostly a negotiating ploy to renew the license under more favorable terms.

        Anyway, I would argue that it's not that simple to just "threaten to sue" -- you have to have a case you can win, it's expensive to bring even a winning lawsuit and it can have a chilling effect on other business partners who may see an eagerness to sue as a reason to not do business with you or to demand other concessions which could damage profitability.

        And a lot of times if you do threaten, you have to follow through. Businesses are often run by egomanics who don't want to be pushed around, even when they're in the wrong. They'll spot a false threat from a mile away and will view failure to follow through accordingly.

        • by Pikoro ( 844299 )

          The nature of their product is such that it can't be made and distributed in any centralized way...

          Then why is it patentable? I wish we could go back to the way it was before, where you had to submit a physical working example of your invention when submitting a patent application. A patent on a business model should not be allowed.

          • by swb ( 14022 )

            Because its made out of concrete and the shipping costs would make it impossible.

    • Yes patent trolls are a very bad thing but let's not exaggerate their impact or how much they matter.

      You say that as someone who is watching patent trolls in the tech sector.
      You'd likely have a different opinion if you watched patent trolls in the medical sector.

      • What do you see in the medical sector?

        • The same thing. Patents being bought and sold between firms that don't implement them. Techniques being locked up due to monetisation reasons. Doctors take the Hippocratic Oath, companies that support them, the medical and pharma industries do not. Look up through the comment lists and you'll find others have already provided cites for medical procedures being unavailable or suddenly spiking in cost due to nothing more than patent trolling.

    • by sjames ( 1099 )

      let's not understate it either. Some people give away practically the entirety of their pay for a patented drug to keep them alive. It's not exactly slavery, but it's not exactly not. People die every year because they couldn't afford a simple life saving device, test, or medication.

  • Non-Precedential (Score:4, Informative)

    by Anonymous Coward on Sunday January 08, 2017 @12:51PM (#53628865)

    For starters, this decision is non-precedential. It was issued by a District court, and not the Federal Circuit or SCOTUS.

    Secondly, per a Law360 article, the reason for the attorneys fees award against the law firm was, per a law360 article:

    The court awarded attorneys’ fees against AlphaCap and its counsel, Gutride Safier LLP, on the theory that AlphaCap and Gutride Safier multiplied the proceedings in this case unreasonably and vexatiously,” McCrary wrote. “The record, however, establishes that it was Gust and its counsel, not AlphaCap and Gutride Safier, who unreasonably and vexatiously multiplied the proceeding.”

    Thus, this ruling has nothing to do with patent trolling being dealt a death blow, but rather unscrupulous counsel being punished.

  • It just means patent lawyers will be more careful how they structure their contracts from now on.
    • It may also mean that patent trolls will be pickier about which cases they take to court. They may still try to extort money from companies by offering to settle out of court, or offering to sell the patent.

  • by Anonymous Coward on Sunday January 08, 2017 @01:28PM (#53629051)

    Yeah, so now you create lots of shell law firms.

    Until the courts go after people PERSONALLY (you know, like they do every time you get a ticket) there will be no change of behaviour.

    Throwing a few lawyers in jail will do so much more for the profession than fining anyone.

    AC

    • by mysidia ( 191772 )

      Until the courts go after people PERSONALLY (you know, like they do every time you get a ticket) there will be no change of behaviour.

      The court has not precluded that. If the lawyer's compensation will be determined by the case they're working On, and their law firm is indigent, then the lawyer is personally a business partner too!

    • Look at the name of an average law firm and you'll see why "shell" firms are a tricky proposition - "Someone and Someone Legal".

      A lawyer's reputation is their business. Their name is the name of their firm. Even if they're incorporated to limit personal liability, having to pay court costs will directly impact their income and their professional reputation. If doing so causes the firm to fold, they're going to have a very hard time staying in private practice.

  • I hope the sue for profit industry gets shutdown.
    • You say that now, but when an insurance company denies a covered expense let's see what you take is on taking someone to court.

  • by Zontar_Thing_From_Ve ( 949321 ) on Sunday January 08, 2017 @02:25PM (#53629307)
    I'm not a lawyer, but my best friend since college is. We're both Americans. I probably know more about how the US legal system really works as a result of this friendship than how almost all non-lawyers do. The truth is that judges don't like to award court costs nor do lawyers really like it when they do this because it discourages lawsuits and lawyers and judges both think that the system is fine just like it is and having fewer lawsuits is actually bad. Some judges won't ever award costs to the winner. Some will only do so to send a message to people they think really abuse the system. It seems to me that this is considered to be an unusual situation rather than something that will set a precedent. Also, judges often ignore anything they feel like, so the fact that court costs got awarded in case A doesn't at all mean that they will be in case B in front of a different judge even if the circumstances that led to the awarded are essentially identically.

    Here's an example. Suppose you have neighbor who doesn't like you and the neighbor sues you for something really stupid and asks for a huge monetary award. Suppose that you win, but the case is extraordinarily difficult and time consuming and you end up ruined financially from having to pay the costs to defend yourself against this frivolous lawsuit. You can probably count on one hand the number of judges and lawyers who actually feel sorry for you. From their perspective the system worked perfectly. You got sued for something bogus and you won. The fact that it destroyed you financially to defend yourself is not their concern. Not at all.
    • and generally come from well to do families. If you've lived your entire life without any major hurdles or problems it's hard to imagine anyone who has. There's a meme for it: What don't the poor just buy more money. It's kinda funny, and an exaggeration, but there's a fair amount of truth in it.
    • by PPH ( 736903 ) on Sunday January 08, 2017 @03:18PM (#53629523)

      This.

      And since contingency fees are one tool that poor and middle class people use to obtain legal assistance, this decision will harm this group to a greater degree.

      To continue with your example: I am quite wealthy, but live in an upper middle class neighborhood (not Warren Buffet, but same idea). So if I decide to file a frivolous lawsuit against a neighbor, I just pay my attorney for her time. So she has no risk. And if I lose, so what? I could wipe out my neighborhood with lawsuits even if my track record in court was 50%. They, on the other hand aren't in line to receive a big settlement. They are defendants, whose best outcome will be a 50% chance of being reimbursed for their expenses. Smart lawyers will avoid such clients, leaving them at a disadvantage in court.

      • What you're saying may be true but it doesn't follow from this example. In your case, if you file a frivolous suit, your neighbors have the potential to win a judgment against you and actually collect it. So if you went on a litigation spree it would be quite harmful. OTOH, if one of your neighbors (assuming they find out your true wealth) was borderline bankrupt, they could potentially see you as a walking ATM machine and sue you frivolously using a lawyer who gets paid on contingency. They have nothin
    • by Kjella ( 173770 )

      Sounds like the courts like to drum up business, how American. Here in Norway the general rule is that the winners are awarded reasonable court costs if their claim is mostly or entirely won, rule of thumb is around 80% for economic damage. That is to say, if I claim $3000 in compensation for lost income and the court awards me $2500+ I'll get court costs covered on top. If I make a bullshit $10000 claim for emotional distress and is awarded $3000 then I have to pay my own costs. The reasoning is that you s

    • Very interesting perspective. Goes to show that there's no justice in this world, only competing self interests.

      BTW, posts like this are the reason why I'm still on Slashdot.

      • This is a great post and a great perspective. I hope the OP gets a +5. But it isn't the same situation referred to in the article.
  • The question is "Do contingency fees make lawers liable for court costs?" If the answer is yes it has implications far beyond punishing patent trolls. Any case involving contingency fes could put lawyers at risk of liability, whether it is a class action, accident claim or any other action involving a contingency fee. The goodness of that is debatable.
    • by sjames ( 1099 )

      Keep in mind, this ruling included misconduct on the part of the law firm beyond simply accepting the case on contingency.

  • by SlaveToTheGrind ( 546262 ) on Sunday January 08, 2017 @03:57PM (#53629727)

    Attorneys fees aren't awarded in garden-variety troll cases, and this decision does absolutely nothing to change that. Here, at a minimum, the plaintiff's attorneys:
        1. Filed suit on a patent that (even by troll standards) was almost certainly invalid after the Supreme Court's Alice decision (issued the year before the suit was filed).
        2. Filed suit in the Eastern District of Texas when there was not even the thinnest veneer of a basis to do so.
        3. After this defendant refused to settle for small potatoes like the others, plaintiff first offered a covenant not to sue (which also would have made the current case go away), then when defendant announced its intent to seek fees, litigated the case for another year and a half in two different states and ran up defendant's costs even more.

    This might give pause to attorneys taking on a handful of really egregious cases around the margins, but IMO isn't going to take very much of a bite out of the troll industry in general -- the game will just shift to the next-higher-quality tier of patents.

    Now, the TC Heartland venue case that the Supreme Court has decided to take [scotusblog.com]? That's the one that could significantly impact the troll community -- keep an eye on it.

    • Because about 90% of patent trolling is done by only a handful of law firms, who all sue on questionable patents in East Texas and generally follow a similar pattern of behavior, this certainly could have a significant effect. Heck, even knocking one of the top five troll firms out of the trolling business would be significant.

      • Because about 90% of patent trolling is done by only a handful of law firms

        I'm curious exactly what "handful"/"five or so" you have in mind. I just pulled up the 8 clusters of cases filed so far this year in the Eastern District of Texas, and what do you know -- 8 different law firms. Similar picture back into December (which is far as I care to look back right now and I think adequately makes the point).

        and generally follow a similar pattern of behavior

        In this situation that's irrelevant even if true. The only way this particular ruling is going to give any trolls much pause is if the vast majority of patents they might asser

        • It's interesting that we have such different information, considering that you seem to be fairly well informed, yet I've received information from multiple reliable sources that doesn't match what you're saying. I am speaking specifically of patent TROLLS, not all cases related to patents.
          You asked which law firms. Austin Hansley and Craig Tadlock filed 10% of all NPE patent cases in 2015. I don't recall other names offhand, but Hansley and Tadlock account for maybe 20% of TROLL suits (guesstimating, becaus

          • Certainly not all such patents have the issue decided in Alice, I didn't say they did. I said they tend to be questionable patents, as applied to the defendants. And they tend to engage in trollish behavior that is disrespectful to the court, as these attorneys did. I suppose that's a bit by definition - trolls act trollish.
            Prenda did the same KINDS of things, which is why they were considered trolls and the courts shut them down. Prenda were of course copyright trolls, but the trollish tactics were the s

          • The main difference is that you're looking at numbers for 2015, which was a significant peak. In 2016, there were 1661 patent cases filed in EDTX (about 35% down from 2015). Of those, Tadlock filed 75 cases (4.5%) and Austin Hansley filed 11 (0.6%). Another secondary difference could be that you're only considering about 50% of the cases filed in EDTX to be troll cases. That's a matter of labeling to some degree, but is somewhat low IMO.

        • > The only way ... if the vast majority of patents they might assert in the future are Alice-susceptible

          I wonder where you get that. I see the holding as essentially:

          Attorneys who file meritless suits on a contingency basis may be liable for costs, especially if they engage in actions which are similar to, but not quite, abuse of abuse of process, malicious prosecution, or barratry. I don't see that Alice ("on a computer") is the key element here.

          Certainly "meritless suits on a contingency basis, wit

          • > The only way ... if the vast majority of patents they might assert in the future are Alice-susceptible

            I wonder where you get that.

            Mainly because that's the only factor that's out of the law firms' control. The rest is a series of deliberate decisions about how they conduct themselves during litigation, and the vast majority know how to keep themselves on the thick side of the ice in that regard. While the Supreme Court's Octane Fitness decision in 2014 arguably made it easier for a court to award attorney's fees, I strongly suspect fees would have been awarded in a case like this even under the old standard.

      • Because about 90% of patent trolling is done by only a handful of law firms, who all sue on questionable patents in East Texas

        Can't we just sell East Texas to Mexico? (and make Trump pay).

  • In a more perfect world, a lawyer's ethical obligations would preclude him from taking on a case that is "obviously frivolous."

    If a judge found that a case was "obviously frivolous" then the judge would be encouraged to fine the lawyer personally and would be required to refer the lawyer to the state bar, which would likely fine him an additional amount equal to what his client paid him for that case. Lawyers who got many such referrals relative to their peers (lawyers with similar caseloads and specializa

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