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In many areas of the legal system, parties are encouraged to settle their disputes without resorting to full-dress litigation.1 Such compromises conserve judicial resources and provide faster, cheaper, and therefore more effective relief.2 To facilitate compromise, courts ordinarily treat settlement agreements as binding and enforceable contracts. In patent disputes, however, the effect of settlement agreements is problematical. Lower federal courts, faced with three Supreme Court decisions4 that are relevant but not dispositive, have created a conflicting body of law, under which settlement agreements are sometimes not enforced at all,5 sometimes enforced in part,6 and sometimes given almost full effect. 7

The Enforceability of Patent Settlement Agreements after Lear, Inc. v. Adkins