Life Technologies Corp. v. Promega Corp.
U.S. Supreme Court · decided February 22, 2017 · Supreme Court Database (Spaeth)
- Decided
- February 22, 2017
- Term
- October Term 2016
- Vote
- 7–0
- Majority author
- Justice Sotomayor
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice SOTOMAYOR delivered the opinion of the Court. This case concerns the intersection of international supply chains and federal patent law. Section 271(f)(1) of the Patent Act of 1952 prohibits the supply from the United States of "all or a substantial portion" of the components of a patented invention for combination abroad. 35 U.S.C. § 271(f)(1). We granted certiorari to determine whether a party that supplies a single component of a multicomponent invention for manufacture abroad can be held liable for infringement under § 271(f)(1). 579 U.S. ----, 136 S.Ct. 2505, 195 L.Ed.2d 838 (2016). We hold that a single component does not constitute a substantial portion of the components that can give rise to liability under § 271(f)(1). Because only a single component of the patented invention at issue here was supplied from the United States, we reverse and remand. I A We begin with an overview of the patent in dispute. Although the science behind the patent is complex, a basic understanding suffices to resolve the question presented by this case. The Tautz patent, U.S. Reissue Patent No. RE 37,984, claims a toolkit for genetic testing. The kit is used to take small samples of genetic material-in the form of nucleotide sequences that make up the molecule deoxyribonucleic acid (commonly referred to as "DNA")-and then synthesize multiple copies of a particular nucleotide…
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