BMC Resources, Inc. v. Paymentech, L.P.
United States Court of Appeals for the Federal Circuit
498 F.3d 1373 (2007)
BMC Resources, Inc. (BMC) (plaintiff) owned a United States patent that claimed a method of processing a complete payment transaction in a single telephone call. Claim 1 of BMC’s patent recited several steps, including prompting a caller to enter an account number associated with a payee, prompting the caller to enter a credit card or debit card number, accessing a remote payment network, and having the remote payment network determine whether sufficient funds exist in the caller’s account to complete the payment transaction. BMC sued Paymentech, L.P. (defendant) for infringement of its patent. BMC’s direct-infringement theory required four parties to perform all of the claimed method steps. Paymentech moved for a summary judgment of noninfringement on the ground that it did not perform all the steps of the claimed method, either by itself or in combination with other parties. The district court granted Paymentech’s motion. BMC appealed. On appeal, the parties agree that Paymentech did not perform every step of the claimed method, but BMC argued that a prior Federal Circuit decision had relaxed the standards for joint infringement.
Rule of Law
Holding and Reasoning (Rader, J.)
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