SAS Institute Inc. v. ComplementSoft, LLC [2016]
825 F.3d 1340 · United States Court of Appeals for the Federal Circuit · United States
Issue
Does literal infringement of a method claim require that each step be performed by a single entity?
Held
Yes – to directly infringe a method claim, a single party must perform all steps or exercise control over the others.
Exam use
In an exam, introduce SAS Institute Inc. v. ComplementSoft, LLC with the citation only if you can remember it accurately; otherwise use the case name and court, then focus on the rule and application. A strong answer should say what SAS Institute Inc. v. ComplementSoft, LLC decided, why the facts mattered, and how the authority helps resolve the new facts. Avoid treating the case as a decorative reference. Use it to prove a doctrinal step in Patent infringement – literal infringement of software method claims, then move quickly to analysis.
Summary
SAS Institute Inc. v. ComplementSoft, LLC is included in the Quantum Computing Law case database because it gives students a concrete authority for Patent infringement – literal infringement of software method claims. The reported citation is 825 F.3d 1340, and the decision is associated with United States Court of Appeals for the Federal Circuit. In revision, treat the case as a way to connect the legal issue to a real dispute rather than as an abstract rule. The key exam move is to state the holding, identify the fact pattern that made the rule matter, and then decide whether a new problem question should apply, distinguish, or limit the authority.
Facts
Procedural History
Issue
Does literal infringement of a method claim require that each step be performed by a single entity?
Held
Yes – to directly infringe a method claim, a single party must perform all steps or exercise control over the others.
Ratio Decidendi
Direct infringement of a method claim requires that the accused infringer either performs every step itself or exercises 'direction or control' over others who perform steps.
Obiter Dicta
Check the linked source for concurring, dissenting, or obiter observations before quoting this case. If the case includes non-binding reasoning, use it as persuasive support rather than as the core rule.
Reasoning
Plain-English Explanation
Essay-Ready Explanation Generator
Version 1 of 4
Reference to SAS Institute Inc. v. ComplementSoft, LLC (825 F.3d 1340) strengthens a Quantum Computing Law answer because the case reflects the principle that Direct infringement of a method claim requires that the accused infringer either performs every step itself or exercises 'direction or control' over others who perform steps. Applied to a problem question, the case should be used after identifying the issue as Does literal infringement of a method claim require that each step be performed by a single entity? The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.
Underlying Concepts
- quantum-computing-law
- Quantum Computing Law
- Patent infringement – literal infringement of software method claims
- case authority
- exam application
Key Passages
- Verify exact wording in the linked source before quoting.
Significance
Related Cases
No related cases listed.
Exam Tips
Revision Checklist
- Name the issue before discussing facts so the marker sees the legal question immediately.
- State the holding in one sentence, then use the ratio to explain why the court reached that result.
- Use the citation and jurisdiction to show why this authority matters for the problem you are answering.
- Pair this case with one supporting or contrasting authority if the question tests limits, policy, or exceptions.
Problem Question Use
Common Pitfalls
- Name-dropping the case without applying the facts
- Ignoring jurisdiction or procedural posture
- Quoting without checking the linked source