Fujitsu Ltd. v. Netgear, Inc.

U.S. Philips Corporation (Philips), LG Electronics, Inc. (LG), and Fujitsu Limited (Fujitsu) (plaintiffs) were part of Via Licensing (Via), a licensing pool that included patents that manufacturers of certain products were required to license. In 2005, Via sent a letter to Netgear, Inc. (defendant), offering to license patents essential to compliance with interoperability standards. The letter referred only to Philips’s patent, which was for a method for transmitting, fragmenting, and defragmenting data messages in a communications network. The software at issue broke coded messages into smaller parts before putting them back together, helping to reliably transfer data. Philips sued Netgear for contributory and induced infringement of Philips’s patent in several Netgear product models. The fragmentation option was disabled by default. With the option enabled, some models only fragmented messages, while others only defragmented them. After the district court had construed the relevant patent claims, Philips, LG, and Fujitsu filed a motion for summary judgment on the grounds that Netgear infringed Philips, LG, and Fujitsu’s patents when Netgear complied with the interoperability standards. The district court denied the motion and held that, though Philips had presented evidence of direct infringement for four products, there must be evidence of infringement for each product allegedly infringed. Philips, LG, and Fujitsu filed a second motion for summary judgment of infringement. Netgear filed a cross-motion for summary judgment of noninfringement. The district court denied Philips, LG, and Fujitsu’s motion and granted Netgear’s cross-motion, finding no contributory infringement and no induced infringement. Fujitsu, LG, and Philips appealed the district court’s construction of claim terms, the denial of the motion for summary judgment of infringement, and the grant of summary judgment of noninfringement.