Limelight Networks, Inc. v. Akamai Technologies, Inc.
United States Supreme Court
572 U.S. 915 (2014)
- Written by Craig Conway, LLM
Facts
Akamai Technologies, Inc. (Akamai) (plaintiff) was the licensee of a patent for a method of delivering web content to end users. One of the steps in Akamai’s method patent was “tagging,” or labeling certain components of its customers’ websites for storage on Akamai’s servers. Limelight Networks, Inc. (Limelight) (defendant) also operated a content-delivery network and employed a number of the steps in Akamai’s method patent, but made its customers carry out the step of tagging their content. Akamai brought a patent infringement suit against Limelight in the United States District Court for the District of Massachusetts. A jury found that Limelight infringed on Akamai’s patent, but the district court granted Limelight’s motion for judgment as a matter of law in light of the intervening decision in Muniauction, Inc. v. Thomson Corp., 532 F.3d 1318 (Fed. Cir. 2008). The United States Court of Appeals for the Federal Circuit reversed the district court, finding that a party can be liable for inducing infringement by showing that there has been direct infringement, even if it cannot show that a single party is liable for direct infringement. The United States Supreme Court granted Limelight’s petition for certiorari.
Rule of Law
Issue
Holding and Reasoning (Alito, J.)
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