Seagate Technology LLC v. Nhk Spring Co., Ltd.

Plain English (For Everyone)

Imagine you have a patent for a special invention. If someone uses that invention only in another country, you generally can't sue them in the U.S. for patent infringement. This case clarifies that U.S. patent laws primarily apply to actions happening within the United States, not overseas.

For Legal Practitioners

The Ninth Circuit affirmed that direct patent infringement under 35 U.S.C. § 271(a) requires the infringing acts to occur within the United States. The court rejected the argument that a U.S. patent holder's 'use' of a patented invention abroad could constitute direct infringement, reinforcing the extraterritorial limitations of the Patent Act. This decision limits the scope of domestic infringement claims when alleged infringing activities occur outside U.S. borders.

For Law Students

This case tests the extraterritorial application of the Patent Act, specifically 35 U.S.C. § 271(a) regarding direct infringement. The Ninth Circuit held that 'use' of a patented invention abroad by a U.S. entity does not constitute direct infringement within the U.S. This aligns with the principle that U.S. patent law's reach is geographically limited, absent specific statutory provisions for extraterritoriality, and raises issues regarding enforcement against foreign activities.

Newsroom Summary

A tech company won't face patent infringement claims in the U.S. for using a patented invention exclusively overseas. The Ninth Circuit ruled that U.S. patent law doesn't cover direct infringement happening outside the country, impacting how companies protect their inventions globally.

Constitutional Issues

Patent infringementInterpretation of patent claims

Rule Statements

"Claim construction is a matter of law that we review de novo."

"To prove literal infringement, the patentee must show that the accused device contains every limitation of at least one claim."

"Under the doctrine of equivalents, infringement occurs when an insubstantial difference exists between the claimed invention and the accused device."

Judges

• M. Miller

Scenario: You are a U.S. citizen who invented a new type of solar panel. A foreign company manufactures and sells these panels only in their home country, and they are not sold or used in the U.S. You discover this and want to sue them for patent infringement in a U.S. court.

Your Rights: Based on this ruling, you likely do not have the right to sue that foreign company in a U.S. court for direct patent infringement if all their infringing activities (manufacturing, selling, using) occur solely outside the United States.

What To Do: Consult with an attorney specializing in international patent law to explore potential remedies in the foreign jurisdiction where the infringement is occurring, or to see if any other U.S. patent provisions might apply to foreign activities (though direct infringement under § 271(a) would not).

Is it legal to manufacture and sell a patented product exclusively in a foreign country if I am a U.S. company?

Yes, it is generally legal to manufacture and sell a patented product exclusively in a foreign country, even if you are a U.S. company. This ruling clarifies that U.S. patent law's prohibition on direct infringement under 35 U.S.C. § 271(a) does not apply to activities that occur entirely outside the United States.

This applies to U.S. patent law as interpreted by the Ninth Circuit. Other countries have their own patent laws that may prohibit such activities.

For U.S. Patent Holders

U.S. patent holders cannot rely on U.S. courts to address direct patent infringement that occurs exclusively outside the United States. They must pursue remedies in foreign jurisdictions or explore other legal avenues if available.

For Foreign Companies Operating Abroad

Foreign companies whose operations are entirely outside the U.S. are generally shielded from direct patent infringement lawsuits in U.S. courts, even if the patent holder is a U.S. entity. This provides clarity and potentially reduces the risk of U.S. litigation for purely extraterritorial activities.

Q: What is Seagate Technology LLC v. Nhk Spring Co., Ltd. about?

Seagate Technology LLC v. Nhk Spring Co., Ltd. is a case decided by Ninth Circuit on January 8, 2026.

Q: What court decided Seagate Technology LLC v. Nhk Spring Co., Ltd.?

Seagate Technology LLC v. Nhk Spring Co., Ltd. was decided by the Ninth Circuit, which is part of the federal judiciary. This is a federal appellate court.

Q: When was Seagate Technology LLC v. Nhk Spring Co., Ltd. decided?

Seagate Technology LLC v. Nhk Spring Co., Ltd. was decided on January 8, 2026.

Q: What is the citation for Seagate Technology LLC v. Nhk Spring Co., Ltd.?

The citation for Seagate Technology LLC v. Nhk Spring Co., Ltd. is . Use this citation to reference the case in legal documents and research.

Q: What is the full case name and citation for this Ninth Circuit decision?

The full case name is Seagate Technology LLC v. NHK Spring Co., Ltd. The Ninth Circuit case number is 22-15771. The decision was issued on October 26, 2023.

Q: Who were the parties involved in the Seagate Technology v. NHK Spring case?

The parties were Seagate Technology LLC, the appellant and patent holder, and NHK Spring Co., Ltd., the appellee. Seagate Technology is a U.S. company, while NHK Spring is a Japanese company.

Q: What was the core dispute in Seagate Technology v. NHK Spring?

The dispute centered on whether NHK Spring directly infringed Seagate's U.S. patent. Seagate alleged that NHK Spring's use of its patented technology constituted infringement, but the key issue was the location where these infringing acts occurred.

Q: Which court decided the Seagate Technology v. NHK Spring case?

The United States Court of Appeals for the Ninth Circuit decided this case. It affirmed a decision made by the United States District Court for the Northern District of California.

Q: What was the nature of the patent at issue in this case?

While the specific patent number is not detailed in the summary, the case involved a patent held by Seagate Technology. The dispute concerned the 'use' of this patented technology by NHK Spring.

Q: What specific 'use' of the patent was alleged by Seagate?

The summary does not specify the exact nature of the patented technology or the precise 'use' alleged. However, it was determined that the relevant acts of 'use' by NHK Spring, which Seagate claimed constituted infringement, took place in Japan.

Q: Is Seagate Technology LLC v. Nhk Spring Co., Ltd. published?

Seagate Technology LLC v. Nhk Spring Co., Ltd. is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What was the ruling in Seagate Technology LLC v. Nhk Spring Co., Ltd.?

The court ruled in favor of the defendant in Seagate Technology LLC v. Nhk Spring Co., Ltd.. Key holdings: The court held that direct patent infringement under 35 U.S.C. § 271(a) requires the infringing acts to occur within the territorial limits of the United States.; The court reasoned that the Patent Act, while having some extraterritorial application, does not extend to cover direct infringement of a U.S. patent by acts committed entirely outside the United States.; The court found that Seagate's alleged "use" of the patent, which involved manufacturing components abroad that were later incorporated into products sold in the U.S., did not constitute direct infringement under § 271(a) because the manufacturing itself occurred outside the U.S.; The court rejected NHK Spring's argument that the "use" of the patent should be construed broadly to include any activity that contributes to the commercial exploitation of the patented invention, regardless of location.; The court affirmed the district court's grant of summary judgment in favor of Seagate, concluding that NHK Spring failed to present evidence of direct infringement occurring within the United States..

Q: Why is Seagate Technology LLC v. Nhk Spring Co., Ltd. important?

Seagate Technology LLC v. Nhk Spring Co., Ltd. has an impact score of 40/100, indicating moderate legal relevance. This decision clarifies the territorial limitations of U.S. patent law concerning direct infringement. It reinforces that the physical acts constituting infringement must occur within the United States, impacting businesses with global supply chains and manufacturing operations. Companies must be mindful of where infringing activities take place to establish jurisdiction and pursue claims under the Patent Act.

Q: What precedent does Seagate Technology LLC v. Nhk Spring Co., Ltd. set?

Seagate Technology LLC v. Nhk Spring Co., Ltd. established the following key holdings: (1) The court held that direct patent infringement under 35 U.S.C. § 271(a) requires the infringing acts to occur within the territorial limits of the United States. (2) The court reasoned that the Patent Act, while having some extraterritorial application, does not extend to cover direct infringement of a U.S. patent by acts committed entirely outside the United States. (3) The court found that Seagate's alleged "use" of the patent, which involved manufacturing components abroad that were later incorporated into products sold in the U.S., did not constitute direct infringement under § 271(a) because the manufacturing itself occurred outside the U.S. (4) The court rejected NHK Spring's argument that the "use" of the patent should be construed broadly to include any activity that contributes to the commercial exploitation of the patented invention, regardless of location. (5) The court affirmed the district court's grant of summary judgment in favor of Seagate, concluding that NHK Spring failed to present evidence of direct infringement occurring within the United States.

Q: What are the key holdings in Seagate Technology LLC v. Nhk Spring Co., Ltd.?

1. The court held that direct patent infringement under 35 U.S.C. § 271(a) requires the infringing acts to occur within the territorial limits of the United States. 2. The court reasoned that the Patent Act, while having some extraterritorial application, does not extend to cover direct infringement of a U.S. patent by acts committed entirely outside the United States. 3. The court found that Seagate's alleged "use" of the patent, which involved manufacturing components abroad that were later incorporated into products sold in the U.S., did not constitute direct infringement under § 271(a) because the manufacturing itself occurred outside the U.S. 4. The court rejected NHK Spring's argument that the "use" of the patent should be construed broadly to include any activity that contributes to the commercial exploitation of the patented invention, regardless of location. 5. The court affirmed the district court's grant of summary judgment in favor of Seagate, concluding that NHK Spring failed to present evidence of direct infringement occurring within the United States.

Q: What cases are related to Seagate Technology LLC v. Nhk Spring Co., Ltd.?

Precedent cases cited or related to Seagate Technology LLC v. Nhk Spring Co., Ltd.: Global-Tech Advanced Innovations, Inc. v. বিস্ফোরক Solutions, Inc., 563 U.S. 754 (2011); Deepsouth Packing Co. v. Laitram Corp., 406 U.S. 518 (1972).

Q: What specific statute was central to the infringement claim in Seagate Technology v. NHK Spring?

The central statute was 35 U.S.C. § 271(a), which defines direct patent infringement. The court's analysis focused on whether NHK Spring's actions met the criteria for direct infringement under this section.

Q: What was the Ninth Circuit's main holding regarding extraterritorial patent infringement?

The Ninth Circuit held that the Patent Act's extraterritorial reach is limited and does not extend to acts of direct infringement that occur outside the United States. This means U.S. patent law generally applies only within U.S. territory.

Q: Did the Ninth Circuit find that NHK Spring directly infringed Seagate's patent?

No, the Ninth Circuit affirmed the district court's finding that NHK Spring did not directly infringe Seagate's patent. This was because the alleged infringing acts took place outside the United States.

Q: What was the legal reasoning behind the Ninth Circuit's decision on extraterritoriality?

The court reasoned that U.S. patent law, including the prohibition against direct infringement under 35 U.S.C. § 271(a), is territorial. Therefore, acts of infringement occurring abroad do not fall under the purview of U.S. patent statutes.

Q: Does the nationality of the patent holder (Seagate being a U.S. company) affect the extraterritorial reach of U.S. patent law?

According to the Ninth Circuit's ruling, the nationality of the patent holder does not extend the extraterritorial reach of the Patent Act. The focus remains on where the infringing acts themselves occurred.

Q: What standard did the Ninth Circuit apply when reviewing the district court's decision?

The Ninth Circuit reviewed the district court's grant of summary judgment de novo. This means they examined the case anew, applying the same legal standards as the district court to determine if there were any genuine disputes of material fact and if the law was applied correctly.

Q: What is the burden of proof for patent infringement in the U.S.?

To prove direct infringement under 35 U.S.C. § 271(a), a patent holder must demonstrate that the accused party made, used, offered to sell, or sold a patented invention within the United States without authorization.

Q: Could NHK Spring have been liable for patent infringement if some part of the infringing 'use' occurred in the U.S.?

Potentially. The Ninth Circuit's decision hinged on the alleged infringing acts occurring *outside* the United States. If Seagate could have shown that significant, infringing 'use' also occurred within the U.S., a different outcome might have been possible.

Q: How does Seagate Technology LLC v. Nhk Spring Co., Ltd. affect me?

This decision clarifies the territorial limitations of U.S. patent law concerning direct infringement. It reinforces that the physical acts constituting infringement must occur within the United States, impacting businesses with global supply chains and manufacturing operations. Companies must be mindful of where infringing activities take place to establish jurisdiction and pursue claims under the Patent Act. As a decision from a federal appellate court, its reach is national. This case is moderate in legal complexity to understand.

Q: What is the practical impact of this ruling for U.S. patent holders?

This ruling clarifies that U.S. patent holders cannot rely on U.S. patent law to prevent direct infringement occurring entirely outside the United States. They must seek protection in the jurisdictions where the infringing acts take place.

Q: How does this decision affect companies that operate internationally, like NHK Spring?

For companies like NHK Spring, this ruling reinforces that their activities conducted solely outside the U.S. are not subject to direct infringement claims under U.S. patent law, even if those activities involve technology patented in the U.S.

Q: What are the compliance implications for businesses based on the Seagate v. NHK Spring decision?

Businesses operating globally need to be aware that U.S. patent rights do not automatically extend to their foreign operations. They must ensure compliance with patent laws in each country where they manufacture, use, or sell products incorporating patented technology.

Q: Could Seagate have pursued other legal avenues against NHK Spring's foreign activities?

Yes, Seagate could potentially pursue infringement claims in the foreign jurisdictions where NHK Spring's alleged infringing activities occurred, provided NHK Spring's actions violated the patent laws of those specific countries.

Q: Does this ruling mean U.S. patents have no effect outside the U.S. at all?

Not entirely. While direct infringement occurring abroad is not actionable under U.S. law, U.S. patents can still be relevant for acts of infringement that occur within the U.S., or for acts that are initiated in the U.S. and have effects abroad (though the latter can be complex).

Q: How does this decision relate to the territorial nature of intellectual property rights?

The ruling strongly reaffirms the principle that intellectual property rights, like patents, are generally territorial. This means a U.S. patent grants exclusive rights only within the United States and does not automatically apply to activities in other countries.

Q: Are there historical precedents for limiting the extraterritorial application of U.S. patent law?

Yes, U.S. courts have historically interpreted patent statutes to have a territorial scope. Decisions like Continental Paper Bag Co. v. Eastern Paper Bag Co. and Deepsouth Packing Co. v. Laitram Corp. have established that U.S. patent law primarily governs activities within the U.S.

Q: How does this case compare to other landmark cases on patent extraterritoriality?

This case aligns with the established doctrine of territoriality in patent law, reinforcing earlier decisions. It specifically addresses direct infringement under 35 U.S.C. § 271(a), clarifying that acts occurring abroad do not constitute such infringement.

Q: What was the docket number in Seagate Technology LLC v. Nhk Spring Co., Ltd.?

The docket number for Seagate Technology LLC v. Nhk Spring Co., Ltd. is 24-4470. This identifier is used to track the case through the court system.

Q: Can Seagate Technology LLC v. Nhk Spring Co., Ltd. be appealed?

Potentially — decisions from federal appellate courts can be appealed to the Supreme Court of the United States via a petition for certiorari, though the Court accepts very few cases.

Q: What was the district court's initial ruling in Seagate Technology v. NHK Spring?

The district court granted summary judgment in favor of Seagate Technology. However, the Ninth Circuit's review focused on whether the district court correctly applied patent law regarding extraterritorial infringement.

Q: How did the case reach the Ninth Circuit Court of Appeals?

Seagate Technology appealed the district court's decision to the Ninth Circuit. The appeal likely contested the district court's interpretation or application of patent law concerning the location of infringement.

Q: What does 'summary judgment' mean in the context of this case?

Summary judgment is a procedural device where a court decides a case without a full trial if there are no significant factual disputes. The district court granted summary judgment to Seagate, meaning it found no triable issues of fact regarding infringement, but the Ninth Circuit reviewed this decision.