• Bulletproofing Method Claims for Post-Limelight Enforcement
  • February 7, 2014 | Author: Michael R. Dzwonczyk
  • Law Firm: Sughrue Mion, PLLC - Washington Office
  • After BMC, the single entity rule served to protect unknowing actors who performed a single step of a claimed method by requiring that a single entity perform all steps of a claimed process or entirely control the use of the process. The federal circuit in Akamai as confirmed that rule for proof of direct infringement under §271(a), but has rejected that rule for proof of indirect infringement under §271(b). The Supreme Court has granted review.