Samsung had argued that it had reason to believe Apple's patents were invalid — so that even if Samsung had infringed, it couldn't be found to have done so willfully. Koh found Samsung's arguments reasonable enough to rule out an overall finding of willful infringement. In other words, she believed Samsung went into the whole situation with a reasonable belief that it wasn't in the wrong.
Koh could potentially reduce the damages owed Apple; however, she has not made any rulings to that effect at this time. She did decline some of Apple's requests to increase damages and ruled that claims 10 and 15 of Samsung's '941 patent were invalid.