Conditional Sale Doesn’t Trigger Patent Exhaustion
Client Alert | 1 min read | 07.10.06
In LG Electronics, Inc. v. Bizcom Electronics, Inc. et al. , (No. 05-1261, July 7, 2006), a Federal Circuit panel affirms in part, reverses in part and vacates in part a district court's summary judgment of non-infringement in favor of third-party installers who purchase microprocessors and chipsets from Intel Corporation, which is itself authorized to sell such products under an agreement with LG Electronics (“LGE”). Under this agreement, however, Intel is required to notify its customers that combining Intel products with non-Intel products is not permitted.
In reversing the district court's holding that the system claims of LGE's asserted patents were “exhausted” by Intel's sales, the panel reasons that requiring Intel to notify its customers that they were prohibited from infringing LGE's combination patents makes both the license and subsequent sales by Intel expressly conditional and, as such, does not trigger the patent exhaustion doctrine.
Insights
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
