Adasa Inc. v. R-Pac International LLC

Background

Adasa brought a patent-infringement complaint against R-Pac International LLC, which the caption identifies as formerly known as RIC Merger Sub LLC and formerly doing business as R-Pac International Corp. R-Pac moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that Adasa had not stated a claim for relief.

Court’s Analysis

Under Rule 12(b)(6), the court evaluates whether the complaint contains enough factual allegations to state a claim that is plausible on its face. The court must accept well-pleaded factual allegations as true and draw reasonable inferences for the plaintiff at this stage.

The court held that Adasa adequately pleaded direct infringement under 35 U.S.C. § 271(a). The complaint alleged that R-Pac operated more than a dozen sales offices in the United States; sold and offered its allegedly infringing products for sale in the United States regardless of where the products were made or encoded; routed orders to domestic offices and servers to generate and transmit encoding data; directed order information to United States offices for invoicing; and had employees in the United States negotiate customer agreements, including product specifications. The court concluded that these allegations were sufficient at the pleading stage, even if an infringing product was made or used abroad.

The court also held that Adasa adequately pleaded induced infringement and contributory infringement under 35 U.S.C. § 271(b) and (c). For induced infringement, the court found sufficient allegations of direct infringement, R-Pac’s knowledge, and R-Pac’s intent to encourage infringement. For contributory infringement, the court found sufficient allegations that R-Pac knew the relevant combination was patented and infringing and that R-Pac’s components had no substantial non-infringing uses.

Disposition

The court denied R-Pac’s motion to dismiss in its entirety. R-Pac must file its answer no later than 14 days after the order’s entry. After the parties join issue, they must follow the court’s procedures for a hearing concerning patent-claim interpretation under Markman v. Westview Instruments, Inc. The Clerk was directed to terminate ECF No. 21.