With Brian McQuillen
On December 28, 2009, in "Forest Group v. Bon Tool Company", the U.S. Court of Appeals for the Federal Circuit rejected long-standing precedent to hold that the plain language of the false marking statute (35 U.S.C. § 292) requires the civil penalty to be imposed on a per-article basis—meaning that a false marking claimant may now recover up to $500 "per falsely marked article".