In In re Bill of Lading Transmission & Processing System Patent Litigation, Nos. 10-1493, -1494, -1495,
-1496, 11-1101, -1102 (Fed. Cir. June 7, 2012), the Federal Circuit affirmed-in-part, reversed-in-part, and remanded the district court’s dismissal with prejudice of R+L Carriers, Inc.’s (“R+L”) amended complaints of indirect infringement, finding that R+L failed to state a claim of contributory infringement but adequately stated a claim of induced infringement. The Court held that, “[t]o state a claim for indirect infringement, . . . a plaintiff need not identify a specific direct infringer if it pleads facts sufficient to allow an inference that at least one direct infringer exists.” Slip op. at 19. Notably, the Court held that direct infringement is sufficiently pleaded as long as the requirements of Form 18 of the Federal Rules of Civil Procedure are met. See this month’s edition of Last Month at the Federal Circuit for a full summary of this decision.