On Oct. 9, the District Court of Illinois issued an opinion stating
that, although the Federal Circuit's comments regarding the relationship
between a request for preliminary injunction and enhanced damages for
infringement after filing of the case were dicta (In re Seagate, 497
F.3d at 1374), the court was still required to preclude the patent owner
from obtaining enhanced damages for infringement occurring after the
filing of the case. The District Court held the patent owner's "remedy
for any post-filing willful infringement was a preliminary injunction."

The holding is in GSI Group, Inc. v. Sukup Manufacturing, 2008 U.S.
Dist. LEXIS 80557.