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Keurig, Incorporated v. Sturm Foods, Inc.
United States Court of Appeals for the Federal Circuit
732 F.3d 1370 (2013)
Keurig, Incorporated (Keurig) (plaintiff) owned two patents disclosing a single-serve coffee brewer and the related method for making beverages. Specifically, the patent claimed a method of brewing coffee whereby a disposable cartridge was inserted into the brewer, pierced, and combined with a hot liquid. Sturm Foods, Inc. (Sturm) (defendant) manufactured and sold Grove Square disposable beverage cartridges for use in Keurig brewers. Keurig sued Sturm, contending that when customers used Sturm’s non-Keurig Grove Square cartridges in Keurig brewers, that conduct infringed Keurig’s method claims. Keurig further contended that Sturm was responsible for inducement and contributory infringement. Sturm moved for summary judgment, raising patent exhaustion as an affirmative defense. The district court granted the motion, concluding that Keurig’s patent rights had been exhausted upon Keurig’s initial sale of the patented brewer. Keurig appealed.
Rule of Law
Holding and Reasoning (Lourie, J.)
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