Global-Tech Appliances, Inc. v. SEB S.A.

Global-Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (2011), is a United States Supreme Court case. The case considered whether a party, in order to "actively [induce] infringement of a patent" under 35 U.S.C. § 271(b), must know that the induced act constitutes patent infringement, or whether deliberate indifference to the existence of a patent can be considered a form of actual knowledge. In an 8–1 decision delivered by Justice Samuel Alito, the Court held that induced infringement requires knowledge of patent infringement, but because the petitioners had knowledge of a patent infringement lawsuit involving the respondent and Sunbeam Products over the same invention, the Federal Circuit's judgement that petitioners induced infringement must be affirmed under the doctrine of willful blindness.

Justice Anthony Kennedy filed a dissenting opinion.

Background

In the late 1980s, respondent SEB, S.A., a French maker of home appliances, invented an innovative deep fryer, the external surfaces of which remain cool-to-the-touch during operation. The "cool-touch" fryer consisted of a framing that suspends the metal frying pot within the plastic housing, leaving an insulating air space between the heated pot and the exterior. SEB obtained U.S. Patent No. 4,995,312 for this design in 1991 and began manufacturing and selling it under the T-Fal brand.