Supplemental Brief — Microsoft Corp. v. AT & T CORP.

—

No. 05-1056

IN THE

Supreme Court of the United States

MICROSOFT CORPORATION,

Petitioner,

v.

AT&T CORP.,

Respondent.

ON PETITION FOR A WRIT OF CERTIORARI TO THE

UNITED STATES COURT OF APPEALS

FOR THE FEDERAL CIRCUIT

SUPPLEMENTAL BRIEF FOR RESPONDENT

IN RESPONSE TO BRIEF OF THE UNITED STATES

STEPHEN C, NEAL SETH P. WAXMAN

JONATHAN G. GRAVES Counsel of Record

NATHAN K. CUMMINGS JONATHAN E. NUECHTERLEIN

COOLEY GODWARD MARK C. FLEMING

KRONISH LLP WILMER CUTLER PICKERING

One Freedom Square HALE AND DORR LLP

Reston Town Center 1875 Pennsylvania Avenue, N.W.

11951 Freedom Drive Washington, D.C. 20006

Reston, VA 20190 (202) 663-6000

(703) 456-8000

LAWRENCE J. LAFARO

THOMAS A. RESTAINO

AT&T Corp.

One AT&T Way

Bedminster, NJ 07921

(908) 532-1850

RULE 29.6 STATEMENT

The Rule 29.6 statement included in the respondent’s

brief in opposition remains accurate.

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TABLE OF CONTENTS

Page

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a 2

I. The Solicitor General’s Answer To The First

Question Presented Compels The Federal Cir-

cuit’s Answer To The Second....................... taal daileecceitiniiaat 2

Ii. Certiorari Is Unwarranted For Additional

Reasons Unrelated To The Merits .0.................cccccccesseeeeee 8

| ___TEEE ree ern TOn ae Vee RN Se ON 10

(iii)

iv

TABLE OF AUTHORITIES

CASES

Page(s)

Deepsout Packing Co. v. Laitram Corp.,

a aaa tena 4

dein & co v. International Harvester Co.,

710 Fl2d 1551 (Fed. Cir. 19838) .............c.cccsssssssecseseses 10

Eolas Techs. Inc. v. Microsoft Corp., 399 F.3d

1325 (Fed. Cir.), cert. denied, 126 S. Ct. 568

eee iciicslattietticapanniceniciclaniensseemsaiilienaneiapinanniaenibiinnininidees 2

General Motors Corp. v. Devex Corp., 461 U.S.

ED inethnhiennsnccnticesticnsiaiiiianendtiveesiiaiatsialiamiintietnanuianes 10

Grain Processing Corp. v. American Maize-

Prods. Co., 185 F.3d 1341 (Fed. Cir. 1999).........0... 10

Oncale v! Sundowner Offshore Services, Inc.,

ee Ee SENET aiiiceiisestninntinabiiecinsniieiilaatiddiacnaatntenipiy 4

Pellegrini v. Analog Devices, Inc., 375 F.3d

1113 (Fed. Cir.), cert. denied, 543 U.S. 1003

24 ieihpteeiiteesinndetadeeeasiaensinineaueaniinnaiaiandepenetitininnenemnnntneite 5

Waymark Corp. v. Porta Systems Corp.,

245 Fi3d 1364 (Fed. Cir. 2001) .............cccccsssessseesees 4,5

STATUTES AND RULES

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LEGISLATIVE MATERIALS

Amendment in the Nature of a Substitute to

H.R. 2795, the “Patent Act of 2005”: Hear-

ing Before the Subcomm. on Courts, the

Internet, and Intellectual Property of the

House Comm. on the Judiciary, 109th

OE 8

BEST AVAILABLE COPY

Vv

TABLE OF AUTHORITIES—Continued

Committee Print Regarding Patent Quality

Improvement: Hearing Before the Subcom-

mittee on Courts, the Internet, and Intellec-

tual Property of the House Committee on

the Judiciary, 109th Cong., 1st Sess. (2005)..

Patent Reform Act of 2006, S. 3818, 109th

SERIE NUIT icivesicsaiestiniinieiitaiedieiadaiaedeidicesdiiniipeaiignitd

130 Cong. Rec. H10525, reprinted in 1984

A Ailes GREE secesnccnmssniatepeacetttineinaaianeintain

OTHER AUTHORITIES

American Heritage Dictionary (2d coll. ed.

Bradley, Curtis A., Territorial Intellectual

Property Rights in an Age of Globalism,

37 Va. J. Int'l L. 506 (1997).........c.cccrcsscssscsssseses

Chisum, Donald S., Normative and Empirical

Territoriality in Intellectual Property:

Lessons from Patent Law, 37 Va. J. Int’! L.

GUS CENT) ansunssansnscensernevenamennssasennsivaiasinnameniiaiii

Page(s)

Respondent AT&T Corp. respectfully submits this sup-

plemental brief in response to the brief filed by the Solicitor

General on September 29, 2006. See Sup. Ct. Rule 15.8.

SUMMARY

1. Although the government ultimately disagrees with

the judgment below, it supports the Federal Circuit’s analy-

sis on what should be the dispositive issue in this case. Ad-

dressing the first question presented in the petition, the So-

licitor General recognizes that “intangible software”—a se-

quence of 1s and 0s—can be a “component” of a patented in-

vention under 35 U.S.C. § 271(f). U.S. Br. 10. Given that

answer, the only remaining question is straightforward: Did

Microsoft supply the “intangible software” at issue here to

its foreign contractors with the intent that it would be “com-

bin{ed]” with millions of computers “in a manner that would

infringe [AT&T’s] patent if such combination occurred

within the United States”? 35 U.S.C. § 271(f)(1); see also id.

§ 271(f)(2). That is precisely what Microsoft did, and the de-

cision below is thus entirely correct.

The government reaches a contrary conclusion only be-

cause, in answering the second question presented in the

petition, it inexplicably forgets its own answer to the first

question presented: that the “component” at issue is “intan-

gible software” (U.S. Br. 10), not the particular physical me-

dia (master disks, electromagnetic impulses, or hard drives)

on which the software is transmitted and stored. The ques-

tion in this case is not whether Microsoft has supplied for-

eign end users with “copies” of hard drives containing the

relevant object code, but whether Microsoft has supplied the

object code itself in the expectation that it would be com-

bined with computers abroad. This basic misunderstanding

pervades the government’s brief. Moreover, the govern-

ment’s various policy rationales for artificially narrowing

Section 271(f) are unsound on the merits and, in any event,

misdirected. Congress, not the Judiciary, should resolve the

complex current debate about the net effect of Section 271(f)

on U.S. economic interests.

2

2. Quite apart from the correctness of the Federal Cir-

cuit’s decision, certiorari is unwarranted for three additional

reasons. First, as the Solicitor General acknowledges, Con-

gress is currently considering legislation that, if enacted,

would repeal Section 271(f) altogether and could require the

Court to dismiss the writ as improvidently granted before it

could decide this case on the merits. Second, the case law

concerning Section 271(f)—and _ particularly Section

271(f)(2)—remains embryonic. Given the technical and eco-

nomic complexity of the policy issues presented here, the

Court should postpone review until after the lower courts

have developed a body of case law addressing the application

of this statutory provision across a range of factual contexts.

Third, it is by no means clear that the second question in

the petition has much real-world significance. For example,

regardless of how Section 271(f) is interpreted, it is undis-

puted that Microsoft separately infringed AT&T’s patent

under 35 U.S.C. § 271(a) by manufacturing and testing in-

fringing devices in the United States. Microsoft must fully

compensate AT&T for all foreseeable damages flowing from

that infringement, including Microsoft’s subsequent exploi-

tation of its U.S.-tested product worldwide, and must place

AT&T in the position it would have occupied but for Micro-

soft’s original violation of Section 271(a). In this and other

cases, a patentee’s ultimate recovery for infringement under

Section 271(a) would often approximate the recovery avail-

able under the Federal Circuit’s interpretation of Section

271(f).

DISCUSSION

I. The Solicitor General’s Answer To The First Ques-

tion Presented Compels The Federal Circuit’s An-

swer To The Second

1. AT&T agrees with the Solicitor General that Section

271(f) applies to all “components” of a patented invention,

“not only tangible components.” U.S. Br. 9; see also Eolas

Techs. Inc. v. Microsoft Corp., 399 F.3d 1325 (Fed. Cir.), cert.

denied, 126 S. Ct. 568 (2005). The Solicitor General correctly

rejects Microsoft’s attempt to exempt all “intangible soft-

3

ware” components from Section 271(f). U.S. Br. 10. The So-

licitor General likewise explains that Microsoft’s analogy to

“design information” and “blueprints” makes no sense be-

cause, unlike software, they are not themselves “combined”

into any infringing product. Jd. at 8. AT&T therefore

agrees with the Solicitor General that the first question pre-

sented does not warrant this Court’s review.

Once the first question is resolved as the Solicitor Gen-

eral advocates, the second question is simple: Did Microsoft

“suppl{y]” the software—the Windows object code incorpo-

rating the speech coder/decoder—to foreign computer manu-

facturers for “combination” with other components into de-

vices that, if made in the United States, would infringe

AT&T's patent? 35 U.S.C. § 271(f). There is no more

straightforward way to describe what Microsoft has done.

To “supply” means to “make available for use; provide” or to

“furnish or equip with.” American Heritage Dictionary 1222

(2d coll. ed. 1991). Here, the Windows software—an intan-

gible sequence of 1s and 0s—is present in the foreign-made

computers only because Microsoft “provided” or “fur-

nished”—in a word, supplied—it from the United States, via

golden master disk or electronic transmission. '

Although the government pays lip service to “the statu-

tory text” (U.S. Br. 11), it offers no actual textual analysis of

the word “supplied.” Nor does it address the many cases in

which courts and, indeed, Microsoft’s own patents refer to

the transmittal of software code as “supplying” software.

Opp. 17-18. Instead, it rejects the Federal Circuit’s conclu-

sion only because, in turning from the first question pre-

sented in the petition to the second, it forgets its own char-

acterization of the “component” at issue. Rather than ask

' The Solicitor General’s suggestion that the Federal Circuit “all but

acknowledged” that Microsoft did not “supply” the software from the

United States (Br. 13) simply misconstrues the Federal Circuit’s lan-

guage. The Federal Circuit followed an interpretation of “supplied” that

comported with the ordinary meaning of the word, the business practices

of the software industry, the purposes of the statute, and the need to

avoid absurd results. Pet. App. 6a-10a.

4

whether Microsoft supplied software—intangible 1s and 0s—

for combination with computers abroad, the government

asks whether Microsoft supplied individual “copies” of

“physical[] embodi{ments]” of software “in the varied orien-

tation of particles in the magnetically sensitive coating on

the surface of the hard disk platters.” U.S. Br. 9; see also id.

at 10 (heading B), 12-13 & n.2. But as the government (cor-

rectly) recognizes earlier in its brief, the issue is whether

Microsoft supplied the Windows object code, a binary se-

quence of numbers that “lacks physical existence.” /d. at 8-9.

The issue is not whether Microsoft supplied each of the indi-

vidual physical containers in which that code is stored and

transmitted.

Indeed, the Solicitor General’s approach would carve

out an atextual and arbitrary “software exception” to the

scope of Section 271(f), given that every provision of soft-

ware necessarily involves “copying” it, in the sense of

“physically embod[ying]’” it in a new medium such as a new

hard drive. U.S. Br. 9. But there is absolutely no indication

that Congress meant to treat software—of which it was

clearly aware when it enacted Section 271(f)—any differ-

ently from any other components of patented inventions.

Nor is there any merit to the Solicitor General’s appar-

ent suggestion (Br. 12) that Section 271(f) narrowly codifies

the position of the dissent in Deepsouth Packing Co. v.

Laitram Corp., 406 U.S. 518 (1972). While Deepsouth was

the catalyst for the enactment of Section 271(f), “statutory

prohibitions often go beyond the principal evil to cover rea-

sonably comparable evils, and it is ultimately the provisions

of our laws rather than the principal concerns of our legisla-

tors by which we are governed.” Oncale v. Sundowner Off-

shore Servs., Inc., 523 U.S. 75, 79 (1998). Indeed, Section

271(f) necessarily creates patent liability for a range of con-

duct beyond the type of activity addressed in Deepsouth.

For example, under Section 271(f)(2), a defendant need not

supply a “substantial portion” of an infringing product’s

components, nor need the component that is supplied be

combined abroad to create an infringing product. See Way-

mark Corp. v. Porta Sys. Corp., 245 F.3d 1364, 1367-1368

5

(Fed. Cir. 2001). Because Section 271(f) cannot be construed

as simply a narrow response to Deepsouth, that case cannot

provide a basis for carving arbitrary exceptions from the

statutory language.

In any event, the Solicitor General is wrong to claim

that the Federal Circuit’s holding “den{ies] companies that

design software in the United States,” unlike companies in

Deepsouth’s position, “any avenue of competing abroad

without the risk of massive patent liability under United

States law for foreign sales.” U.S. Br. 15. U.S. software

manufacturers can still perform much of the fundamental

research that goes into software development and, without

fear of liability, convey their ideas to foreign manufacturers

for the creation of software that, if combined with a com-

puter in the United States, would constitute an infringement

under Section 271(a). The Federal Circuit does not preclude

a company in Microsoft’s position from providing foreign

companies with technical specifications—the software

equivalent of blueprints—for particular types of software

programs. See Pellegrini v. Analog Devices, Inc., 375 F.3d

1113 (Fed. Cir. 2004). What Microsoft may not do is what it

did here: supply the actual software that will itself be “com-

bined” with devices that would infringe patents if manufac-

tured in the United States.

2. The government’s reliance on the “presumption

against extraterritorial application” (U.S. Br. 16-17) is mis-

placed for three reasons. First, Microsoft has been held li-

able not for conduct performed abroad, but for conduct per-

formed in the United States with the knowledge that the

conduct may have particular consequences abroad. The do-

mestic character of the infringement is particularly clear un-

der Section 271(f)(2), which makes a company liable for send-

ing specially-designed components out of the United States

with the intent that they be combined in a manner that

would infringe a U.S. patent, regardless of whether the

components actually are so combined. See Waymark Corp.,

245 F.3d at 1367-1368.

Second, the presumption against extraterritoriality is

designed for the typical statute in which Congress is silent

6

on the question of foreign applicability. It makes little sense

to invoke that presumption as a basis for disregarding the

language of a statute that, like this one, was enacted for the

sole and express purpose of addressing the interplay be-

tween U.S. and foreign law. The very premise of Section

271(f) is that, in the circumstances defined by that provi-

sion’s plain language, U.S. patentees should not have to rely

exclusively on foreign patent protections, which would re-

quire the patentee to assume prohibitive costs to prosecute

and enforce patents in scores of foreign jurisdictions, all

simply to address domestic activity by U.S. companies like

Microsoft that supply components of the patented invention

from the United States.

Third, there is likewise no empirical basis for the Solici-

tor General’s suggestion (Br. 17) that U.S. patentees could in

fact secure sufficient protection simply by obtaining patents

abroad, for “U.S. intellectual property laws are often more

protective than those of other countries.” See Curtis A.

Bradley, Territorial Intellectual Property Rights in an Age

of Globalism, 37 Va. J. Int’ L. 505, 506-507 (1997). And to

the extent that some foreign jurisdictions do provide as

much patent protection as U.S. law, as the United States has

long urged them to do, companies in Microsoft’s position

could hardly complain about the Federal Circuit’s decision as

a policy matter, for such companies would face exactly the

same liability abroad that they face in United States under

the Federal Circuit’s construction of Section 271(f). The only

difference is that they would face such liability without im-

posing needless transaction costs on holders of U.S. patents

(in the form of prosecuting foreign patents and securing for-

eign judgments). Neither Microsoft nor the Solicitor Gen-

eral identifies any neutral reason for imposing such economic

waste on the developers of intellectual property.

3. The Solicitor General’s policy concerns about the de-

cision below are similarly without merit. The Solicitor Gen-

eral speculates, without any clear foundation, that applying

Section 271(f) as written “could ultimately” lead some soft-

ware companies to relocate operations abroad. Br. 18 (em-

phasis added). As an initial matter, this argument quarrels

7

not so much with the Federal Circuit’s decision as with Con-

gress’s decision to enact Section 271(f) in the first place. No

matter how it is interpreted, that provision has always pre-

sented the hypothetical risk that manufacturers of “compo-

nents” would move their operations offshore. See Donald S.

Chisum, Normative and Empirical Territoriality in Intel-

lectual Property: Lessons from Patent Law, 37 Va. J. Int’! L.

603, 607 (1997) (calling for repeal of Section 271(f)). Con-

gress nonetheless decided to protect U.S. patentees from

unfair competition by U.S. “component” manufacturers.

Furthermore, the Solicitor General’s concern about off-

shore migration of component manufacturers focuses on only

one isolated economic factor among many. The Federal Cir-

cuit’s decision accomplishes the basic economic purpose of

the patent laws: it encourages innovation in the U.S. by en-

suring effective intellectual property protection, from which

software developers (including Microsoft) unquestionably

benefit.’ The Federal Circuit’s approach also removes tne

artificial incentives that Microsoft’s position would give to

end-product manufacturers (in this particular case, the for-

eign computer manufacturers) to locate their operations off-

shore in order to exploit Microsoft’s proposed software ex-

ception to Section 271(f). Under Microsoft’s position, any

’ 4 . , °

“ As one senior U.S. executive recently testified:

The software industry could achieve cost savings by moving its

development and production facilities overseas, but it has cho-

sen to remain in the United States and has flourished here, in

no small part because the copyright, trade secret and judicial

processes in the United States provide[] strong and effective

protection for the intellectual property content of software

products. There is no justification for letting them enjoy the

benefit of our strong IP system for their own products while, at

the same time, they are allowed to avoid exposure to other

companies’ patents when those same products are exported.

Committee Print Regarding Patent Quality Improvement: Hearing Be-

fore the Subcomm. on Courts, the Internet, and Intellectual Property of

the House Comm. on the Judiciary, 109th Cong., Ist Sess. 202 (2005)

(statement of Jack Haken, Vice President, Intellectual Property & Stan-

dards, U.S. Philips Corporation).

8

manufacturer that depends on U.S.-developed software

gains substantial savings (7.e., avoidance of patent royalties)

by locating its manufacturing facilities abroad. A proper

construction of Section 271(f) levels the playing field among

jurisdictions by ensuring that patent-related costs will be

the same wherever the manufacture occurs. See 130 Cong.

Rec. H10525, reprinted in 1984 U.S.C.C.A.N. 5827 (stating

that Section 271(f) was enacted “to avoid encouraging manu-

facturing outside the United States”). In sum, as U.S. ex-

ecutives have emphasized to Congress, there is no consensus

about the net effect of 271(f) on U.S. economic interests.’

The responsibility for resolving that empirical controversy

rests with Congress, not this Court.

II. Certiorari Is Unwarranted For Additional Reasons

Unrelated To The Merits

Even apart from the correctness of the Federal Cir-

cuit’s decision on the merits, certiorari should be denied for

three additional reasons. First, as the Solicitor General

notes (Br. 19 n.4), Congress is considering a comprehensive

patent reform bill that, among other things, would repeal

Section 271(f) in its entirety. See Patent Reform Act of 2006,

S. 3818, 109th Cong. § 5(f) (2006). Although AT&T and oth-

ers vigorously oppose such a repeal, the pendency of this bill

shows that Congress is fully capable of amending the patent

laws if it reverses course and concludes that Microsoft’s pol-

* There is currently a sharp difference of opinion within the IP

stakeholder community as to whether, in the future, Section

271(f) will result in a net increase or decrease in U.S. jobs.

Those who favor its repeal argue that Section 271(f) discour-

ages certain jobs (such as software design jobs) from remaining

in the U.S., while opponents of the repeal just as passionately

argue that Section 271(f) protects other kinds of jobs (such as

assembly jobs) from foreign outsourcing.

Amendment in the Nature of a Substitute to H.R. 2795, the “Patent Act of

2005”: Hearing Before the Subcomm. on Courts, the Internet, and Intellec-

tual Property of the House Comm. on the Judiciary, 109th Cong., Ist

Sess. 68 (2005) (statement of Phil Johnson, Chief Patent Counsel, Johnson

& Johnson).

9

icy concerns (echoed here by the Solicitor General) are valid.

It also shows that, if certiorari were granted, the writ might

need to be dismissed as improvidently granted if Section

271(f) is in fact repealed before this case is decided.

Second, this Court’s review of Section 271(f) would be

premature. There are very few decisions interpreting that

provision in general and Section 271(f)(2) in particular. That

paucity of case law is significant because, as the Solicitor

General acknowledges, similar Section 271(f) issues could

arise in a host of different contexts, some involving software

and some involving “other high-technology industries.” U.S.

Br. 18. If this Court were to intervene at this early stage in

the judicial consideration of Section 271(f), it would preter-

mit the case-by-case analysis across a range of diverse tech-

nological settings that, over the long term, would likely pro-

duce the soundest body of precedent in a complex legal field.

Third, further consideration in the lower courts may

well confirm that the parties’ interpretive dispute about Sec-

tion 271(f) has little ongoing practical significance in the first

place, given the availability of alternative damages theories

that could subject defendants in Microsoft’s position to the

same general degree of liability even if the decision below

were reversed. For example, quite apart from Section

271(f), Microsoft indisputably infringed AT&T’s patent un-

der Section 271(a) by making and using an infringing device

in the United States in the course of developing, testing, and

debugging the Windows software. See Pet. App. 42a, 45a.’

But for that enormously consequential threshold act of in-

fringement, Microsoft would not have developed the final

* See 35 U.S.C. § 271(a) (“(WJhoever without authority makes, uses,

offers to sell, or sells any patented invention, within the United States . . .

infringes the patent.”). Moreover, even apart from this threshold viola-

tion of Section 271(a), the Solicitor General appears to agree (Br. 16) that

sending a golden master disk or an electronic transmission to a foreign

computer manufacturer constitutes, under Section 271(f), at least “one act

of supply.” Even “one act of supply” renders the infringer liable for

“damages adequate to compensate for the infringement.” 35 U.S.C. § 284.

10

version of the software that it later supplied to its computer

manufacturing customers in the United States and abroad.

A patentee that successfully claims infringement is enti-

tled to “full compensation for ‘any damages’ [the patent

owner] suffered as a result of the infringement,” General.

Motors Corp. v. Devex Corp., 461 U.S. 648, 654 (1983), a re-

covery measure that includes “any foreseeable lost profits”

that the patentee would have earned “but for’ the infringe-

ment,” Grain Processing Corp. v. American Maize-Prods.

Co., 185 F.3d 1341, 1349 (Fed. Cir. 1999). Thus, a defendant

must make a plaintiff whole by placing it in the same posi-

tion the plaintiff foreseeably would have occupied if the de-

fendant had committed no infringement at all.” For that rea-

son, it is far from clear that resolution of the legal issues

presented in the petition will have “ongoing practical impor-

tance” (U.S. Br. 17), given these alternative doctrinal bases

for the same damages awards that would be available under

the Federal Circuit’s interpretation of Section 271(f).

CONCLUSION

The petition for a writ of certiorari should be denied.

> A plaintiff could be made whole in this respect not just under a

“lost profits” theory of damages, but also under a “reasonable royalty”

theory. 35 U.S.C. $ 284. For example, in negotiating a reasonable royalty

for Microsoft to license AT&T’s patent in order to test Windows software

in the United States for ultimate shipment abroad, AT&T naturally would

have taken into account the amounts that Microsoft expected to gain from

foreign sales of computers that included the U.S.-tested software. See,

e.g., Deere & Co. v. International Harvester Co., 710 F.2d 1551, 1558-1559

(Fed. Cir. 1983).

STEPHEN C. NEAL

JONATHAN G. GRAVES

NATHAN K, CUMMINGS

COOLEY GODWARD

KRONISH LLP

One Freedom Square

Reston Town Center

11951 Freedom Drive

Reston, VA 20190

(703) 456-8000

LAWRENCE J. LAFARO

THOMAS A. RESTAINO

AT&T CORP.

One AT&T Way

Bedminster, NJ 07921

(908) 532-1850

OCTOBER 2006

Respectfully submitted.

SETH P. WAXMAN

Counsel of Record

JONATHAN E. NUECHTERLEIN

MARK C. FLEMING

WILMER CUTLER PICKERING

HALE AND DORR LLP

1875 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

(202) 663-6000