News & Analysis as of

Component Parts Doctrine Appeals

Snell & Wilmer

Component-Part Manufacturers Are Not Required to Indemnify Retail Sellers Under California’s Song-Beverly Consumer Warranty Act...

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The California Court of Appeal in Mega RV Corp. v. HWH Corp. (2014) 225 Cal.App.4th 1318 held that component-part manufacturers are not obligated to indemnify retail sellers under California Code of Civil Procedure section...more

Nutter McClennen & Fish LLP

Product Liability 2021 Year in Review

Massachusetts federal and state courts issued several important product liability decisions in 2021. Nutter’s Product Liability practice group reviewed these cases and report on their significant holdings as follows...more

Faegre Drinker Biddle & Reath LLP

Whether Asbestos-Containing Components Were Manufactured by Third Parties No Longer Matters in New Jersey

Aligning with neighboring New York, and clearing up conflict within the Appellate Division, the New Jersey Supreme Court ruled equipment manufacturers can be held strictly liable on the basis of failure to warn for...more

McDonnell Boehnen Hulbert & Berghoff LLP

Arctic Cat Inc. v. Bombardier Recreational Products Inc. (Fed. Cir. 2020)

The patent marking statute, codified at 35 U.S.C. § 287(a) appears straightforward: Patentees, and persons making, offering for sale, or selling within the United States any patented article for or under them, or importing...more

Blank Rome LLP

The Supreme Court Adopts a Middle of the Road Approach When Deciding a Manufacturer’s Duty to Warn in the Context of Maritime Tort...

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On March 19, 2019, the U.S. Supreme Court in Air & Liquid Systems Corp. v. Devries held that, under maritime law, a product manufacturer has a duty to warn of asbestos or other hazardous parts when its own product, although...more

Beveridge & Diamond PC

Too Much to “Bare”: US Supreme Court Rejects Bare Metal Defense Under Federal Maritime Law

In an eagerly anticipated decision by the asbestos bar, the United States Supreme Court in Air & Liquid Systems et al. v. DeVries et at., Dkt. No. 17-1104, 2019 WL 1245520 (March 19, 2019) rejected the “bare metal defense” as...more

Polsinelli

U.S. Supreme Court Rejects Asbestos Defendants “Bare Metal Defense” in Maritime Cases

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In Air & Liquid Sys. Corp. et al. v. DeVries et al., No. 17-1104 (March 19, 2019), the U.S. Supreme Court held that under federal maritime law, a product manufacturer has a duty to warn when its product requires the...more

Pillsbury - Gravel2Gavel Construction & Real...

SCOTUS Limits “Bare Metal Defense”

On March 19, the U.S. Supreme Court decided the case of Air & Liquid Systems Corp. v. Devries, affirming the ruling of the U.S. Court of Appeals for the Third Circuit in this maritime tort case involving the availability of...more

Cozen O'Connor

SCOTUS Rejects Bare Metal Defense in Maritime Products Liability Actions Involving Asbestos Exposure

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On March 19, 2019, the U.S. Supreme Court decided the first case involving maritime law in several years. In Air & Liquid Systems Corp. et al v. Devries, et al, 586 US ___ (2019), Justice Kavanaugh, writing for the majority...more

Husch Blackwell LLP

U.S. Supreme Court Narrows “Bare Metal Defense” For Maritime Asbestos Cases

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In its decision Tuesday, the U.S. Supreme Court held, under maritime law, that manufacturers can be held liable for injuries caused by asbestos-containing parts manufactured and added to their products by third parties. The...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Air & Liquid Systems Corp. v. DeVries

On March 19, 2019, the Supreme Court decided Air & Liquid Systems Corp. v. DeVries, No. 17-1104, holding that in the maritime tort context, a product manufacturer has a duty to warn when: 1) its product requires incorporation...more

Sunstein LLP

July 2018 IP Update: In Limited Circumstances, the Supreme Court Permits Businesses to Recover Patent Damages for Sales Made...

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The Supreme Court recently answered the question whether a patent owner can collect damages caused by an infringer’s sales outside the U.S. Federal law typically reaches only conduct within the country, but the justices made...more

Knobbe Martens

Federal Circuit Review - July 2018

Knobbe Martens on

Determining Whether a Claim Element or Combination of Elements Would Have Been Well-Understood, Routine, and Conventional Is a Question of Fact - In Aatrix Software, Inc. v. Green Shades Software, Inc., Appeal No....more

Jackson Walker

Extraterritorial Reach Of Patents— Impact Of Recent Supreme Court Decisions

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Jackson Walker partner Leisa Talbert Peschel spoke at the 14th Annual Advanced Patent Litigation Course on Thursday, July 12, at the U.S. Patent and Trademark Office’s Rocky Mountain Regional Office in Denver, Colorado. ...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

WesternGeco v. ION Geophysical

Lost Foreign Profits Awarded as Damages - It is an act of infringement under U.S. patent law to supply “in or from the United States” certain components of a patented invention with the intent that they “will be combined...more

Nutter McClennen & Fish LLP

WesternGeco LLC v. ION GeoPhysical: U.S. Supreme Court Issues Decision on Patent Damages

On June 22, the Supreme Court issued its opinion in WesternGeco LLC v. ION GeoPhysical, which addresses the ability of a patent owner to collect lost profits from sales abroad for infringement under 35 U.S.C. § 271(f)(2)....more

Eversheds Sutherland (US) LLP

Component vs. Complete - the US Supreme Court imposes extraterritorial lost profits damages on parties that violate section...

On June 22, 2018, the US Supreme Court clarified the scope of permissible patent damages awards by holding that when a party is found liable under 35 U.S.C. § 271(f) for exporting components of a patented invention, foreign...more

McDonnell Boehnen Hulbert & Berghoff LLP

Promega Corp. v. Life Technologies Corp. (Fed. Cir. 2017)

At about this time last year, the Supreme Court reversed the Federal Circuit's determination that there are circumstances in which a party may be liable for infringement under 35 U.S.C. § 271(f)(1) for supplying or causing to...more

Knobbe Martens

Federal Circuit Review - December 2017

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Claims Directed to Methods for Streaming Audiovisual Data Held Unpatentable Under § 101 - In Two-Way Media Ltd v. Comcast Cable Communications, Appeal Nos. 2016-2531, 2016-2532, the Federal Circuit affirmed the district...more

Knobbe Martens

Federal Circuit Review | March 2017

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Federal Circuit Remands IPR Final Decision For Inadequate Obviousness Analysis, Sidesteps Issue of Proper Claim Construction Standard - In Personal Web Technologies, LLC v. Apple, Inc., Appeal No. 2016-1174, the Federal...more

McDermott Will & Emery

Export of Single Component of Patented Combination Does Not Impose Liability Under § 271(f)(1)

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In reversing the US Court of Appeals for the Federal Circuit, an essentially unanimous Supreme Court of the United States ruled that the “supply of a single component of a multi-component invention for manufacture abroad does...more

Knobbe Martens

Life Technologies Corp. v. Promega Corp.: Supreme Court Limits Patent Infringement Liability for Suppliers Under § 271(f)(1)

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The Supreme Court in Life Technologies Corp. v. Promega Corp held that providing a single component of a multicomponent invention for manufacture abroad does not give rise to patent infringement liability under 35 U.S.C. §...more

Foley & Lardner LLP

One is Not Enough – Infringement Liability under § 271(f)(1)

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In Life Technologies Corp. v. Promega Corp., Slip Op. 14-1538 (Feb. 22, 2017), the U.S. Supreme Court held that the supply of a single component of a multicomponent invention for manufacture abroad does not give rise to...more

Burr & Forman

Supreme Court Decision Limits Patent Infringement Risk for Exporting a Single Component of a Multi-Component Invention

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On February 22, 2017, the Supreme Court held that there is no patent infringement when an entity supplies "a single component" from the United States for combination into "a multicomponent invention" outside the United...more

Jones Day

Supreme Court Addresses Scope of Patent Infringement Under Section 271(f)(1)

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Section 271(f)(1) of the Patent Act provides that a party infringes a patent claim when it "supplies or causes to be supplied in or from the United States all or a substantial portion of the components of a patented invention...more

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