In this patent infringement action, Apple filed a motion to dismiss Maxell’s induced infringement claims. In the motion, Apple asserted that the complaint did not plausibly allege Apple had “specific intent” to induce infringement, arguing that the complaint only cited broadly to Apple’s website and user manuals, without alleging how the instructions directed Apple’s customers to use the accused products in an infringing manner.
The district court stated that Apple incorrectly asserted that the complaint includes “nothing more than citations to Apple’s user guides and websites . . . .” To the contrary, the district court found that Maxell alleged significantly more. “The complaint sets out detailed allegations of direct infringement, identifying the accused functionalities and accused devices for each patent. The complaint further includes screen-shots and descriptions of Apple’s online user manuals and advertisements, which the complaint alleges contain ‘descriptions and demonstrations’ of the accused functionalities. Some of the pictured webpages appear to contain directions for customers to use the accused functionalities. … The complaint further alleges that Apple’s customers directly infringe the patents by using the accused products in accordance with Apple’s instructions and that Apple provides customers instructions on how to infringe the patents with its user manuals and websites.”