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2013

Proving Induced Infringement and Why the District Court Overturned a Jury's $600M Verdict Against Apple

Posted By Dominick Severance, Sep 17, 2012

Mirror Worlds sued Apple for direct and induced infringement of its method patent.  The jury found Apple liable and awarded Mirror Worlds $600 million. The Federal District Court entered a judgment as a matter of law for Apple overturning the jury's verdict.  The Federal Circuit affirmed on the basis that Mirror Worlds failed to provide evidence that Apple directly infringed the method patent or induced infringement in its users.  In ruling that Mirror Worlds did not prove induced infringement, the Federal Circuit noted that Mirror Worlds could have, but failed to, prove induced infringement in two ways. First, Mirror Worlds could have provided evidence that Apple's user manuals contained actions that covered all of the claims in the method patent together. Regarding this option, the Federal Circuit held that since Apple's manuals contain the infringing actions in different sections and were thus not presented to the user together in the same section, Mirror World's mere production of the manuals was insufficient to prove induced infringement. Second, Mirror Worlds could have proved induced infringement by providing evidence that one of Apple's users performed the actions. The Federal Circuit held that Mirror Worlds did not produce any evidence showing that at least one Apple user performed all the actions in the method patent. Thus, since Mirror Worlds did not produce evidence that Apple directly infringed or induced infringement, Apple was not liable for infringement and the district court's judgement as a matter of law as correct. 

Source PDF (Federal Circuit): http://www.cafc.uscourts.gov/images/stories/opinions-orders/11-1392.pdf