R+L Carriers, Inc. v. DriverTech LLC
681 F.3d 1323
| Fed. Cir. | 2012Background
- R+L appealed the district court’s dismissal with prejudice of amended complaints and counterclaims against six entities for alleged indirect infringement of the '078 patent in the less-than-a-load trucking industry.
- The district court held the amended complaints failed to plausibly plead either direct infringement or indirect infringement under Twombly/Iqbal.
- The '078 patent teaches automating the transfer of shipping documentation data from on-board vehicles to a remote processing center to create loading manifests.
- Form 18 guidance was used by the district court to assess direct infringement pledges, with the court concluding insufficiency.
- On appeal, the court holds all six amended complaints plausibly plead direct infringement and induced infringement, but not contributory infringement, and remands for related declaratory judgment issues.
- There is a concurrent dissent by Judge Newman criticizing the panel’s reliance on Form 18 over Twombly/Iqbal while concurring in part on induced infringement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pleading direct infringement adequacy under Form 18 | R+L argues district court erred by not recognizing adequate direct infringement pledges. | Appellees contend the amendments lacked detailed element-by-element facts. | Direct infringement pled sufficiently under Form 18 standard. |
| Pleading indirect infringement without naming a direct infringer | R+L contends indirect infringement may be pled via circumstantial factual allegations. | Appellees argue Form 18 limits direct infringement pleading; indirect claims require more. | Indirect infringement plausibility sustains where direct infringement can be inferred; no need to name a specific direct infringer. |
| Sufficiency of contributory infringement claims | R+L asserts accused products lack substantial noninfringing uses, supporting §271(c). | Appellees argue products have substantial noninfringing uses and thus no contributory infringement. | Contributory infringement claim properly rejected; products have substantial noninfringing uses. |
| Sufficiency of induced infringement claims | R+L pleads that Appellees induced customers to infringe with knowledge and intent. | Appellees argue statements are too general and do not show specific intent. | Induced infringement claims plausibly stated; district court erred in dismissing them. |
| Declaratory judgments mootness after dismissal | R+L seeks declaratory judgments notwithstanding. | District court found mootness due to dismissal of indirect infringement claims. | Remanded to address declaratory judgment issues consistent with induced-infringement ruling. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must show plausible entitlement to relief)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) (plausibility standard; not mere conclusory statements)
- McZeal v. Sprint Nextel Corp., 501 F.3d 1354 (Fed. Cir. 2007) (Form 18; direct infringement pleading sufficiency not requiring element-by-element proof)
- Lucent Techs., Inc. v. Gateway, Inc., 580 F.3d 1301 (Fed. Cir. 2009) (indirect infringement can rely on circumstantial evidence of unknown direct infringers)
- Ricoh Co. v. Quanta Computer Inc., 550 F.3d 1330 (Fed. Cir. 2008) (substantial noninfringing uses inquiry in contributory infringement)
- Vita-Mix Corp. v. Basic Holdings, Inc., 581 F.3d 1317 (Fed. Cir. 2009) (substantial noninfringing use standard for contributory infringement)