Limelight Networks, Inc. v. Akamai Technologies, Inc.

Akamai Technologies, Inc. (plaintiff) licensed a method patent for delivering web content that included a "tagging" step labeling website components for storage on Akamai's servers; Limelight Networks, Inc. (defendant) operated a competing content-delivery network performing most of the patented method's steps but requiring its own customers to independently carry out the tagging step. Akamai sued for infringement, and a jury found Limelight liable, but the district court granted Limelight judgment as a matter of law based on the intervening Muniauction decision, which held that infringement of a method patent requires all steps be attributable to a single defendant, whether directly or via agency law. The Federal Circuit reversed, holding a party could be liable for inducing infringement upon a showing of direct infringement even without a single party liable for direct infringement, and the Supreme Court granted certiorari.