See Wing Shing Prods. (BVI) Co. Ltd. v. Sunbeam Prods., Inc., 665 F. Supp. 2d 357, 359-60 (S.D.N.Y. 2009) ("[Defendant] advances four independent grounds for summary judgment: invalidity of the [allegedly infringed] patent; collateral estoppel; non-infringement; and laches. . . . Because the Court finds as a matter of law that the accused devices do not infringe the [] patent, it need not address [the] other arguments."), aff'd, No. 2010-1039, 2010 WL 1784720 (Fed. Cir. May 5, 2010). The Federal Circuit has consistently held that "only a limited universe of circumstances warrant a finding of exceptionality in a patent case: `inequitable conduct before the PTO; litigation misconduct; vexatious, unjustified, and otherwise bad faith litigation; a frivolous suit or willful infringement.'"