Case Summary
**Case Summary: Akamai Technologies, Inc. v. Limelight Networks, Inc.**
**Docket Number:** 2601258
**Court:** United States Court of Appeals for the Federal Circuit
**Date:** Decision issued in 2015
**Background:**
Akamai Technologies, Inc. filed a lawsuit against Limelight Networks, Inc. regarding patent infringement related to Akamai's content delivery network technology. Akamai holds patents that cover methods for delivering content over the Internet. The focal point of the dispute was whether Limelight's network infringed on Akamai's patents, particularly concerning the method claims under U.S. Patent No. 6,108,703.
**Key Legal Issues:**
The principal legal question in this case was whether Limelight could be found liable for direct infringement when it allegedly performed some steps of a patented method while its customers performed the remaining steps. This raised substantial issues regarding the doctrine of "divided infringement," which occurs when multiple parties perform different steps of a claimed method.
**Court Findings:**
Initially, the district court ruled in favor of Akamai, determining that Limelight’s actions constituted direct infringement. However, Limelight appealed the ruling, arguing that it could not be held liable because it did not perform all the steps of the patented method itself—some steps were performed by their users.
The Federal Circuit ultimately had to address whether "one party must perform all steps of a method claim" to be liable for direct infringement. The court ruled that for a company to be liable for patent infringement, it must perform or control all steps of the patented method itself or have another entity perform the steps under the direction or control of the accused infringer.
**Outcome:**
In its ruling, the Federal Circuit reversed the district court's determination, establishing that for direct patent infringement to occur, the entity must be responsible for performing all steps of the patented method. This case significantly impacted the way patent law treats divided infringement and set a precedent for future cases involving multiple parties performing separate steps of a patented process.
**Implications:**
The decision highlighted the complexities of patent law concerning method claims and raised important considerations for technology companies about how their services interact with patented methods. The ruling reinforced the necessity for clear ownership or control over each step of a patented process to establish direct infringement.
This case is noteworthy in the realm of intellectual property, particularly for businesses in the technology sector, as it influences how they design their operational frameworks to avoid potential infringement issues.