Commil USA, LLC v. Cisco Systems, Inc. (2014)
- Docket
- 13-896
- Decided
- 2014-01-01
Summary
Question: Is a good-faith belief that a patent is invalid a defense to a claim of induced infringement? Conclusion: No. Justice Anthony M. Kennedy delivered the opinion for the 6-2 majority. The Court held that, although precedent established that liability for induced infringement required knowledge, infringement and validity are separate matters, and the knowledge requirement does not extend to patent validity. To permit a defense of belief in invalidity “would conflate the issues of infringement and validity.” Because a patent is presumed to be valid, if belief in invalidity were a defense to induced infringement, then the force of that presumption would be lessened significantly. Additionally, the Court held that allowing a good-faith belief in the patent’s invalidity to be a defense would burden the courts by creating increased litigation regarding the recognition of such invalidity. Therefore, a defendant’s good-faith belief that a patent is invalid is not a defense to a claim of induced infringement. Justice Antonin Scalia authored a dissenting opinion in which he argued that good-faith belief in a patent’s invalidity is a defense to induced infringement because knowledge of infringement is a requirement for induced-infringement liability, and there can be no infringement (and hence no knowledge of infringement) of an invalid patent. Chief Justice John G. Roberts, Jr. joined in the dissent. Justice Stephen G. Breyer did not participate in the discussion or decision of this case.