Microsoft Corp. v. AT&T Corp., 550 U.S. 437 (2007)
Primary Holding
Under U.S. patent law, specifically §271(f) of the Patent Act, a party is not liable for patent infringement when software is sent from the United States to a foreign entity, and the copies used for installation on foreign-made computers are made abroad, as the original transmission does not constitute supplying components from the U.S.
In the case of Microsoft Corp. v. AT&T Corp., the Supreme Court decided that Microsoft isn't responsible for patent infringement when it sends software from the U.S. to another country, and that software is then copied and used on foreign-made computers. This is important because it means that companies can develop and share software internationally without worrying about infringing on U.S. patents if the software is copied and installed abroad. For consumers, this case is relevant when considering the availability and pricing of software products, as it can affect how companies operate globally and bring technology to different markets.
AI-generated plain-language summary to help you understand this case
In Microsoft Corp. v. AT&T Corp., the underlying dispute arose from AT&T's assertion that Microsoft infringed its patent related to an apparatus for digitally encoding and compressing recorded speech. AT&T claimed that Microsoft's Windows operating system, which includes software capable of processing speech as described in the patent, constituted infringement. The critical issue was whether Microsoft's liability extended to computers manufactured abroad that were loaded with Windows software copied from a master disk or transmitted electronically from the United States. The procedural history of the case began with AT&T suing Microsoft for patent infringement, leading to a ruling by the United States Court of Appeals for the Federal Circuit. The case was subsequently brought before the Supreme Court on a writ of certiorari, where the justices were tasked with interpreting the applicability of Section 271(f) of the Patent Act to the facts of the case. This section, enacted in 1984, addresses patent infringement related to the supply of components from the United States for combination abroad. The relevant background context includes the general principle of U.S. patent law, which typically does not apply extraterritorially, meaning that patent infringement claims are generally limited to activities within the United States. Section 271(f) was introduced to address a specific loophole identified in the Supreme Court's earlier decision in Deepsouth Packing Co. v. Laitram Corp., where it was determined that a company could avoid infringement by exporting parts of a patented invention for assembly abroad. The Supreme Court's decision in this case clarified that Microsoft was not liable under §271(f) because it did not export the copies of the software that were actually installed on the foreign-made computers.
Whether Microsoft is liable for patent infringement under 35 U.S.C. §271(f) when its software is sent from the United States to a foreign manufacturer and subsequently copied and installed on computers made and sold abroad.
The judgment of the Court of Appeals is affirmed.
- Court
- Supreme Court
- Decision Date
- February 21, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
Quanta Computer, Inc. v. LG Electronics, Inc., 553 U.S. 617 (2008)
Consumer WonThe doctrine of patent exhaustion applies to method patents, and the authorized sale of components that substantially embody the patents in suit exhausts the patent rights associated with those components.
eBay Inc. v. MercExchange, L. L. C., 547 U.S. 388 (2006)
Consumer LostA federal court considering whether to award permanent injunctive relief in patent infringement cases must apply the traditional four-factor test used in equity, which requires the plaintiff to demonstrate irreparable injury, inadequacy of legal remedies, a balance of hardships favoring the plaintiff, and that the public interest would not be disserved by the injunction.
MGM Studios, Inc. v. Grokster, Ltd., 545 U.S. 913 (2005)
Consumer LostOne who distributes a device with the object of promoting its use to infringe copyright, as shown by clear expression or other affirmative steps taken to foster infringement, is liable for the resulting acts of infringement by third parties.
Will v. Hallock, 546 U.S. 345 (2006)
Consumer LostThe refusal to apply the judgment bar of the Federal Tort Claims Act is not subject to collateral appeal, as it does not constitute a final decision under 28 U.S.C. §1291.