Quanta Brief: 901424607

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Brief of Dell Inc., Hewlett-Packard, Co., Cisco Systems, Inc., and Ebay Inc. as Amici Curiae in Support of Petitioners


  • This brief notes alternative technology and computer manufacturers that typically incorporate Intel computer components into their products, along with numerous other components from a wide variety of sources. Thus it is shown that the actions of Quanta Computer, Inc. in using Intel microprocessors and other parts in combination with non-Intel components is not outside the reasonable and expected method of manufacturing in the art. In essence, they were not doing anything that would be considered immoral or unjust given precedents of standard practice in the field.
  • Another argument is that if the Courts were to revise the doctrine of patent exhaustion as seen fit by the Federal Circuit Court, the result would be unjust in that manufacturers could claim multiple royalties on the same patent. The computer systems discussed here are very complex and the manufacturing processes involve multiple uses of the same products at many different stages. If the lower court's ruling were to stand, a patent owner could claim royalties at every individual step that involved the product in question, and this adds unnecessary costs to the manufacturing process, and harms both the manufacturers and the public who is to benefit from these machines. Thus, this hinders the goals of the patent system.
  • It is argued that the Federal Circuit Court's revision of the patent exhaustion doctrine to not apply to method patents is against the principles of the patent system. The stated purpose of the patent system is to promote the progress of the useful arts by granting a monopoly incentive to inventors of new and useful things. The owner of a patent is granted the monopoly on the patented subject matter as an economic reward. However, if the patent owner chooses to sell his or her invention and receive an economic reward accordingly, then it is not just to the public that he or she should be able to continue to hold a monopoly on that subject material. This argument demonstrates that there should be limitations to the amount of rewards available to a patent owner.