Jazz Photo Corp. v. United States Int'l Trade Comm.
Court of Appeals for the Federal Circuit
264 F.3d 1094 (2001)
Fuji accused Jazz Photo (defendant/appellant) of infringing its single-use camera patents by refurbishing used cameras for resale abroad and importing them into the U.S., triggering a Tariff Act complaint before the International Trade Commission. Reconstruction of a patented product is prohibited, but repair is allowed; the parties agreed the refurbished cameras met every patent claim limitation, so the case turned on whether Jazz Photo's activities were repair or reconstruction. The Commission found infringement and issued a cease-and-desist order, and Jazz Photo appealed.
Whether an accused infringer who disassembles a single-use patented article and replaces several unpatented elements to allow reuse has committed infringement.