December 30, 2016
Authored and Edited by Christopher B. McKinley; Li Feng, Ph.D.
In Medgraph, Inc. v. Medtronic, Inc., 843 F.3d 942 (Fed. Cir. 2016), during the case’s pendency, the law on direct infringement of method claims changed to hold parties liable for the infringing steps of another if performance of those steps were conditioned on receipt of a benefit. Despite this change, the CAFC affirmed the district court’s summary judgment of noninfringement, holding that appellant Medgraph Incorporated lacked the facts necessary to meet the new standard. Further discussion of the decision can be found on Finnegan’s Federal Circuit IP Blog.
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