Case Study: Centillion V. Qwest

Law360, New York (February 7, 2011, 2:12 PM EST) -- On Jan. 20, 2011, the Federal Circuit addressed for the first time direct infringement of a “system” claim based on “use” where multiple actors are in physical possession of different elements of the system. Centillion Data Sys. LLC v. Qwest Comm. Int’l Inc., No. 2010-1110, -1131, slip op. at 7 (Fed. Cir. Jan. 20, 2011).

In a number of recent decisions, the Federal Circuit held that a patented process cannot be directly infringed through use by multiple actors, absent one actor controlling or directing the performance...
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