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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.

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Client Alert | 4 min read | 11.18.25

DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes

On November 14, 2025, the U.S. Department of Justice (DOJ) announced a sweeping series of enforcement actions, including four guilty pleas and more than $15 million in civil forfeitures against the  Democratic People’s Republic of Korea (DPRK or North Korea) for remote information technology (IT) worker schemes. These actions underscore the federal government’s escalating focus on the exposure of U.S. companies to North Korean IT worker infiltration, following a series of U.S. Government action against the DPRK....