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

179 L. Ed. 2d 1167 · Supreme Court of the United States · 2011

Facts

SEB S.A. invented and patented a "cool-touch" deep fryer, selling it in the U.S. under the T-Fal brand. In 1997, Sunbeam Products, Inc. asked Pentalpha Enterprises, Ltd. to supply deep fryers. Pentalpha purchased an SEB fryer in Hong Kong, copied its design, and then sought a right-to-use opinion without disclosing the copying. The attorney failed to find SEB's patent, and Pentalpha began selling its fryers to Sunbeam, which resold them in the U.S. After SEB sued Sunbeam, Pentalpha was notified of the lawsuit but continued selling fryers to other retailers for U.S. resale.

Procedural history

SEB sued Pentalpha for direct and induced infringement, and a jury found for SEB on both theories, including willful infringement. The District Court rejected Pentalpha's post-trial motion challenging the induced infringement finding due to lack of knowledge. The Court of Appeals for the Federal Circuit affirmed, holding that deliberate disregard of a known risk of a protective patent was a form of actual knowledge. The Supreme Court granted certiorari to address the knowledge requirement for induced infringement.

Issue

Does active inducement of patent infringement under 35 U.S.C. § 271(b) require the inducer to know that the induced acts constitute patent infringement?

Holding

Yes, induced infringement under § 271(b) requires knowledge that the induced acts constitute patent infringement, and this knowledge can be established through the doctrine of willful blindness. The Court affirmed the judgment because the evidence supported a finding of Pentalpha's knowledge under this doctrine.

Rule

Induced patent infringement under 35 U.S.C. § 271(b) requires knowledge that the induced acts constitute patent infringement. This knowledge can be proven under the doctrine of willful blindness, which applies when a defendant subjectively believes there is a high probability a fact exists and takes deliberate actions to avoid learning that fact. This standard is more stringent than recklessness or negligence, implying the defendant "almost actually knew" the critical facts. The Court reasoned this knowledge requirement aligns with that for contributory infringement under § 271(c), given their common statutory origins.

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Case brief last reviewed 2026-09-21. Prepared by CaseReader from the published opinion.