Limelight Networks v. Akamai Technologies (2013)
- Docket
- 12-786
- Decided
- 2013-01-01
Summary
Question: Did the Federal Circuit court err in holding that a defendant may be liable for inducing patent infringement under § 271(b) even if no party committed direct infringement under §271(a)? Conclusion: Yes. Justice Samuel A. Alito, Jr. wrote the opinion for the unanimous Court. The Court held that liability for inducement can only be found when there is direct patent infringement. Because patent rights extend only to the claimed combination of steps, there is no direct patent infringement unless all the steps are carried out. The Court also held that conduct that would be infringing in altered circumstances cannot be the basis of liability for inducement. The Court declined to rule on the merits of the Federal Circuit's rule for direct patent infringement, which states that a single party must perform or exercise "control or direction" over each step of the patented process.