The intent element is satisfied only if the applicant (or his attorneys/agents) deliberately attempted to deceive the United States Patent and Trademark Office. If the information was withheld or misrepresented by the applicant because of an innocent mistake, the applicant did not commit inequitable conduct. At one time, certain courts considered gross negligence to be sufficient intent to warrant a finding of inequitable conduct. See, e.g., Driscoll v. Cebalo, 731 F.2d 878, 885 (Fed. Cir. 1984). However, in Kingsdown Medical Consultants v. Hollister Inc., 863 F.2d 867 (Fed. Cir. 1988), this was reversed -- a deliberate intent to deceive the patent office is now specifically required. Note, however, such a deliberate intent can be proven with indirect or circumstantial evidence. Also, it is often thought that the more "material" the information, the less the required showing of "intent" before the patent will be held to be unenforceable.