Quanta Computer, Inc. v. LG Electronics, Inc. (901422129)
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Read for 4/29/11
Reading Notes
- Decided by the USSC in 2008
- Decide if patent exhaustion applies to the sale of components of a patented system that must be combined with additional components in order to practice the patented method
- USSC says the sale did exhaust patents because the doctrine applies to method patents and the license authorizes the sale of components that substantially embody the patents
- Different than the CAFC
- LGE licensed a patent portfolio to Intel which permits them to make and sell chipsets that use the LGE patents
- License limitations
- No third party
- Claims to not alter rules of patent examination
- License did not extend to any product made by combining an Intel product with any non-Intel product
- Quanta purchased from Intel and made computers using Intel parts with non-Intel memory and buses in ways that practice LGE patents
- Eliminating method patents from exhaustion would seriously undermine the doctrine
Patent Exhaustion
- Doctrine provides that the initial authorized sale of a patented item terminates all patent rights to that item
