## Facts

- Gerald N. Pellegrini owned U.S. Patent No. 4,651,069, directed to brushless motor-drive circuits.
- Analog Devices, Inc. designed and sold ADMC series motor-control integrated circuit chips used in brushless motor systems.
- Pellegrini alleged infringement based on the chips’ use as components in motors assembled abroad.
- The chips at issue were manufactured outside the United States, sold to foreign customers, and incorporated into foreign products.
- The chips were never shipped to or from the United States and were not alleged to have been imported into or sold within the United States.
- Pellegrini proceeded under 35 U.S.C. § 271(f)(1), arguing Analog “supplied or caused to be supplied” components “from the United States” because Analog’s U.S. operations approved, controlled, or directed the foreign manufacture and sales.

## Issues

1. Whether a U.S. company can incur liability under 35 U.S.C. § 271(f)(1) when the accused components are manufactured and sold entirely abroad and never physically exported from the United States, but the foreign activity is directed or authorized from the United States.
2. Whether “supplies or causes to be supplied in or from the United States” in § 271(f)(1) can be satisfied by domestic design, instructions, or managerial control absent a physical supply/export of the components from U.S. territory.

## Decision

- The Federal Circuit affirmed the district court’s partial summary judgment of noninfringement.
- Section 271(f)(1) did not apply because the components at issue were manufactured and sold entirely outside the United States and were never shipped from the United States.
- Domestic authorization, direction, or control of foreign manufacturing and sales did not constitute “supplying” or “causing to be supplied … from the United States” under § 271(f)(1).

## Legal Principles

- U.S. patent infringement is generally territorial; courts apply a presumption against extending liability to purely foreign conduct absent clear statutory authorization.
- Liability under 35 U.S.C. § 271(f)(1) requires supplying (or causing to be supplied) the components themselves “in or from the United States,” which entails a physical provision/export of components from U.S. territory.
- Domestic design work, corporate decision-making, or instructions that lead to foreign manufacture and foreign sales do not satisfy § 271(f)(1) when no components are shipped from the United States.

## Conclusion

The Federal Circuit held that § 271(f)(1) reaches the export-based supply of components from the United States for foreign combination, not situations where a U.S. firm merely directs foreign manufacture and foreign sales of components that never enter U.S. commerce or travel from U.S. territory.


Pellegrini v. Analog Devices, Inc., 375 F.3d 1113 (Fed. Cir. 2004)