InLimelight v. Akamai, 134 S.Ct. 2111 (2014), the Supreme Court held that a defendant may not be liable for inducing infringement of a method patent under 35 U.S.C. §271(b) when no single party has directly infringed the patent by carrying out all steps of the claimed method.  The Court reversed the Federal Circuit’s en banc decision which held that “§271(b) liability arises when a defendant carries out some steps constituting a method patent and encourages others to carry out the remaining steps. . . .”  The Court found that it was undisputed that defendant Limelight does not perform the claim step of tagging components to be stored on its servers, which Limelight requires its customers to do.  Notably, the Court did not decide the issue of joint infringement and whether Limelight committed direct infringement by exercising “control or direction” over the entire method as held by the Federal Circuit in Muniauction v. Thomson, 532 F.3d 1318 (Fed. Cir. 2008), and whether the Muniauction rule is correct.  The Court remanded this issue to the Federal Circuit “to revisit the §271(a) question if it so chooses.”  The Court also did not decide the question of inducing infringement when claims are directed to a product or apparatus, which the Federal Circuit en banc panel found is always present for such claims “because the entity that installs the final part and thereby completes the claimed invention is a direct infringer.”  692 F.2d at 1305-06.