Scope of Direct Infringement Expanded When Multiple Parties Involved
Dr. Richard Chinn, reports
In Travel Sentry v. Tropp, the Fed. Cir. vacated the district court's grant of summary judgement of noninfringement based on direct and indirect infringement theories, identifying three errors by the district court of 1) misidentifying the relevant "activity" at issue; 2) misapprehended the types of "benefits" which can satisfy Akamai V's first prong ; and mischaracterized the required "condition" of a third party's participation in performance of one or more claim step.