PATENTS - After Akamai v. Limelight (decided June 2, 2014)

Akamai holds that “inducement liability may arise ‘if, but only if, [there is] direct infringement’" by one "entity" that "controls" all the steps. But there are no changes to contributory infringement law. 

From what seems to be the first post-Akamai case:

Liability for contributory infringement arises “if a party sells or offers to sell, a material or apparatus for use in practicing a patented process, and that ‘material or apparatus' is material to practicing the invention, has no substantial non-infringing uses, and is known by the party ‘to be especially made or especially adapted for use in an infringement of such patent.’ “ In re Bill of Lading, 681 F.3d at 1337 (quoting 35 U.S.C. § 271(c) and citing Cross Med. Prods., Inc. v. Medtronic Sofamor Danek, Inc., 424 F.3d 1293, 1312 (Fed.Cir.2005)).

Emerson Elec. Co. v. Suzhou Cleva Elec. Appliance Co., Ltd., 4:13-CV-01043 SPM, 2014 WL 2481135 (E.D. Mo. June 3, 2014) (decided one day after Akamai).