McKession Technologies, Inc.v. Epic Systems Corp.

McKesson holds a patent on an electronic means of communication between doctors and patients and sued Epic, which licenses software to medical providers, for infringement. The district court entered summary judgment for Epic. The Federal Circuit affirmed. McKesson failed to demonstrate that a single party directly infringes the patent and could not succeed on its claim of indirect infringement. Customers to whom Epic licenses software neither directly perform the âinitiating a communicationâ step nor exercise control or direction over another who performs this step; no single party infringes the entire method claimed by the patent. Expanding the rules governing direct infringement to reach independent conduct of multiple actors would subvert the statutory scheme for indirect infringement.