Limelight Networks v. Akamai Technologies
In brief
The Supreme Court overturned the ruling against Limelight, saying encouraging infringement requires someone to directly infringe under § 271(a) or another statute.
- Where it stands
- Decided
Decided 9-0 · June 2, 2014 · Opinion by Justice Alito
- What it’s about
- Akamai claimed Limelight encouraged patent infringement, and the Federal Circuit allowed liability despite no direct infringement under § 271(a).
- Who it affects
- The ruling meant Akamai could not hold Limelight liable for encouraging infringement without someone directly infringing under § 271(a) or another statute.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that liability for encouraging infringement requires someone to directly infringe under § 271(a) or another statute, overturned the Federal Circuit’s ruling, and sent the case back to the lower court (remanded).
The dispute turned on how two federal patent-law provisions fit together: one covers direct infringement, and the other covers encouraging infringement.
Question presented
Did the Federal Circuit court err in holding that a defendant may be liable for inducing patent infringement under § 271(b) even if no party committed direct infringement under §271(a)?
What the Court decided
Holding
A defendant is not liable for inducing infringement under §271(b) when no one has directly infringed under §271(a) or any other statutory provision. 692 F. 3d 1301, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said liability under § 271(b) for encouraging infringement requires someone to directly infringe under § 271(a) or another statute.
The vote
What's next
The case returns to the Federal Circuit for further proceedings.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Limelight
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.