The line of attorney fee cases following Octane Fitness continues to grow.  In Raniere v. Microsoft and AT&T (Fed. Cir. 2018), the Federal Circuit affirmed a district court case finding Raniere liable for attorney fees.  In so doing, the court further established that district courts have discretion in attorney fee awards and such findings are reviewed with deference on appeal to the Federal Circuit.  Most interestingly, the court found the plaintiff’s conduct to be contumacious.