Civil Litigation,
Intellectual Property,
Corporate
Feb. 15, 2018
Federal Circuit illuminates two-prong direct infringement test
A ruling clarifies that parties without a contractual relationship who each perform separate steps of a method claim can satisfy the Akamai divided infringement test.





Andrea Jill Weiss Jeffries
Partner
Jones Day
Email: ajeffries@jonesday.com
Stanford Univ Law School; Stanford CA
Andrea is a partner in the IP Practice in the firm's Los Angeles office. She has handled formidable intellectual property disputes involving patents, trade secrets, and other forms of IP for more than 20 years.

Steven J. Corr
Partner
Jones Day
555 S Flower St 50FL
Los Angeles , California 90071
Email: sjcorr@jonesday.com
Loyola Law School; Los Angeles CA
Steven is a partner in the IP Practice in the firm's Los Angeles office.

Jasper L. Tran
Associate
Jones Day
Email: jaspertran@jonesday.com
Jasper is an associate in the IP Practice in the firm's San Francisco office.
As 2017 came to a close, the U.S. Court of Appeals for the Federal Circuit issued its opinion in Travel Sentry, Inc. v. Tropp, illuminating how the Federal Circuit's two-prong test may be applied to find liability for direct patent infringement where there is no contract between the multiple actors each performing different steps of the method claim. 877 F.3d 1370 (Fed. Cir. 2017).
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