Quanta Computer, Inc. v. LG Electronics, Inc. | |
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Argued January 16, 2008 Decided June 9, 2008 | |
Full case name | Quanta Computer, Inc., et al., Petitioners, v. LG Electronics, Inc. |
Docket no. | 06-937 |
Citations | 553 U.S. 617 (more) 128 S. Ct. 2109; 170 L. Ed. 2d 996; 2008 U.S. LEXIS 4702; 76 USLW 4375; 86 U.S.P.Q.2d 1673 |
Case history | |
Prior | Summary judgment denied, finding of non-infringement, LG Elecs., Inc. v. Asustek Computer, Inc., 248 F. Supp. 2d 912 (N.D. Cal. 2003); reversed in part and remanded, LG Elecs., Inc. v. Bizcom Elecs., Inc., 453 F.3d 1364 (Fed. Cir. 2006) (finding that license language sufficient to create limited license and exhaustion doctrine does not apply to method claims); cert. granted, 551 U.S. 1187 (2007). |
Holding | |
Patent license language insufficient to create limited license and avoid effect of exhaustion doctrine; exhaustion doctrine applies to method claims and to authorized sale of article that substantially embodies claimed invention. | |
Court membership | |
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Case opinion | |
Majority | Thomas, joined by unanimous |
Quanta Computer, Inc. v. LG Electronics, Inc., 553 U.S. 617 (2008), is a case decided by the United States Supreme Court in which the Court reaffirmed the validity of the patent exhaustion doctrine.[1] The decision made uncertain the continuing precedential value of a line of decisions in the Federal Circuit that had sought to limit Supreme Court exhaustion doctrine decisions to their facts and to require a so-called "rule of reason" analysis of all post-sale restrictions other than tie-ins and price fixes.[2] In the course of restating the patent exhaustion doctrine, the Court held that it is triggered by, among other things, an authorized sale of a component when the only reasonable and intended use of the component is to engage the patent and the component substantially embodies the patented invention by embodying its essential features. The Court also overturned, in passing, that the exhaustion doctrine was limited to product claims and did not apply to method claims.
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