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Microsoft Corp. v. i4i Ltd. Partnership

564 U.S. 91, 131 S. Ct. 2238, 180 L. Ed. 2d 131 (2011)

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Microsoft Corp. v. i4i Ltd. Partnership

United States Supreme Court

564 U.S. 91, 131 S. Ct. 2238, 180 L. Ed. 2d 131 (2011)

Facts

i4i Limited Partnership and Infrastructures for Information Inc. (plaintiff) (collectively, i4i) held a patent on a method of editing computer documents. i4i brought a patent-infringement suit against Microsoft Corporation (defendant) in federal district court. Microsoft counterclaimed for a declaration of patent invalidity, arguing that software sold by i4i more than a year before the filing of the patent application embodied the claimed invention, thus triggering the on-sale bar. Microsoft also argued that invalidating prior art existed but had not been reviewed by the United States Patent and Trademark Office (PTO) examiner during the application process. The court held that Microsoft faced a burden of proving invalidity by clear and convincing evidence and that Microsoft had failed to meet that burden. The United States Court of Appeals for the Federal Circuit affirmed. Microsoft appealed to the United States Supreme Court, arguing that the burden of proving invalidity should be a preponderance of the evidence—a lesser standard than clear and convincing evidence—at least for the prior-art issue, if not for general invalidity.

Rule of Law

Issue

Holding and Reasoning (Sotomayor, J.)

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