Over the last few years, the cry for reform of the U.S. patent system has grown louder as entities that do not manufacture or sell products have reaped large rewards by claiming that some of the most commercially successful products in the marketplace developed and marketed by   bellwether technology companies infringe their patent rights. This cry is amplified through a perception held by some that certain district courts are more favorable to patent owners and that this favoritism may effectively place a crippling tax on innovators through excessive damage awards. Though there is still much debate over what should be reformed, if anything, to address a perceived damages problem, a damages provision has been a mainstay of the currently proposed Patent Reform Act of 2007.