Quanta brief - 901338276

Quanta Computer, Inc. (petitioners) v. LG Electronics, Inc. (respondent)

Brief of Amicus Curiae Motorola, Inc. in Support of Petitioners

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• Motorola is submitting a brief because it will be significantly affected by the Court's ruling:
  • Motorola, very much like Intel, owns thousands of U.S. patents as well as third-party patents through license agreements.
  • Motorola, like Quanta, often purchases components from suppliers and assembles them into its own products.
  • For these reasons, Motorola is seeking clarification from the Court regarding the patent exhaustion doctrine and is siding with Quanta in this case.

Motorola's arguments in favor of Quanta:

• Motorola agrees with Quanta's defense that United States v. Univis Lens Co. sets the precedent for this case. Since the products Intel licensed from LGE and sold to Quanta have no substantial use except to be combined with other components in a way that infringes LGE's patents, LGE's patents have therefore been exhausted due to its license to Intel.
• Patent law is meant to reward an inventor for the sale and use of his invention. The law makes no effort to restrain the use and enjoyment of the invention once it has been sold. LGE's actions go against this principle because it is trying to gain a second payment for its patents. LGE cannot sell a license to Intel, and then also have the benefit of limiting the rights of Intel's customers to use those patents.

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