Commil Usa, LLC v. Cisco Systems, Inc.

135 S.Ct. 1920 (2015)

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Nature of the Case

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Facts

P brought this action against D alleging that Cisco had infringed P’s patent by making and using networking equipment. P alleged that D had induced others to infringe the patent by selling the infringing equipment for them to use, in contravention of P’s exclusive patent rights. The jury concluded that P’s patent was valid and that D had directly infringed. The jury awarded $3.7 million in damages. As to induced infringement, the jury found D not liable. P filed a motion for a new trial on induced infringement and damages, which the District Court granted because of certain inappropriate comments D’s counsel had made during the first trial. A month before the second trial D went to PTO and asked it to reexamine the validity of P’s patent. The Office granted the request; but, it confirmed the validity. As a defense to the claim of inducement, D argued it had a good-faith belief that D’s patent was invalid. The Court ruled that D’s proffered evidence of its good-faith belief in the patent’s invalidity was inadmissible. D appealed and the Court of Appeals concluded it was error for the District Court to have instructed the jury that D could be liable for induced infringement if it “‘knew or should have known’” that its customers infringed. The Court of Appeals reasoned that “evidence of an accused inducer’s good-faith belief of invalidity may negate the requisite intent for induced infringement.” The Supreme Court granted certiorari.