Iris Corporation v. Japan Airlines Corporation, 769 F.3d 1359

IRIS owns U.S. Patent No. 6,111,506 on a secure identification document with an embedded chip.
JAL examines passports in the United States under federal law, including security and border acts.
IRIS alleges JAL infringed the ’506 patent under 35 U.S.C. § 271(g) by processing electronic passports in U.S. facilities.
IRIS sued in the Eastern District of New York; JAL moved to dismiss for failure to state a claim.
The district court dismissed, applying conflict-of-laws reasoning; IRIS appeals the ruling.
Key issue is whether § 1498(a) provides the exclusive remedy and applies here.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §1498(a) apply to JAL's passport-examination activities?	IRIS argues acts are for the United States under §1498(a).	JAL and lower court rely on conflict with patent law and non-§1498(a) applicability.	Yes; acts are for the United States under §1498(a).
What constitutes government authorization and benefit to qualify as 'for the United States'?	Government authorization/consent is present; actions serve governmental objectives.	Authorization alone is required; benefit to government must be shown as well.	Government authorization plus benefit to the government satisfied; actions are for the United States.

Advanced Software Design Co. v. Fed. Reserve Bank of St. Louis, 583 F.3d 1371 (Fed. Cir. 2009) (government benefit and authorization matter for §1498(a) scope)
TVI Energy Corp. v. Blane, 806 F.2d 1057 (Fed. Cir. 1986) (authorization may be express or implied)
Sevenson Envtl. Servs., Inc. v. Shaw Envtl., Inc., 477 F.3d 1361 (Fed. Cir. 2007) (government benefits from private compliance; and consent)
Madey v. Duke Univ., 413 F. Supp. 2d 601 (M.D.N.C. 2006) (uses-for-government test and benefit requirement)
Zoltek Corp. v. United States, 672 F.3d 130 (Fed. Cir. 2012) (en banc; §1498(a) encompasses §271(g) infringement)