Pellegrini v. Analog Devices, Inc.

Gerald Pellegrini (plaintiff) owned a patent on brushless motor-drive circuits. Analog Devices, Inc. (Analog) (defendant), a company headquartered in the US, manufactured circuit chips, including a type of chip called the ADMC chip. In August 2002, Pellegrini sued Analog for infringement of his patent, claiming that the ADMC chips, when combined with other elements in brushless motors, were overly similar to his invention in a manner constituting infringement. Analog moved for summary judgment, asserting that because its ADMC chips were manufactured, sold, and shipped outside of the US, US patent law did not apply to them. Pellegrini also moved for summary judgment, arguing that because Analog was headquartered in the US and oversaw the manufacture and sale of the chips from within US territory, the chips should be considered as falling within the reach of US patent law. Specifically, Pellegrini invoked 35 U.S.C. § 271(f)(1)’s provision extending liability for patent infringement to actors supplying or causing to be supplied in or from the US the components of patented inventions. He argued that although the ADMC chips were not made, sold, or imported into the US, they were nevertheless subject to US patent law because of the corporate supervision emanating from within the US. The district court granted Analog’s motion and denied Pellegrini’s. Pellegrini appealed.