Clifford R. Lamar, II Image

Clifford R. Lamar, II

is an attorney with Butler Snow‘s Business Services Group and Intellectual Property Group. He focuses his practice on intellectual property litigation and on patent procurement worldwide in a diverse array of technology fields.  He also counsels clients on patent clearance and M&A due diligence involving intellectual property assets.

Recent Articles by Clifford R. Lamar, II

Supreme Court Reverses Federal Circuit, Confirms that One is Still the Loneliest Number

In yet another reversal of the Federal Circuit, the Supreme Court yesterday held that liability under § 271(f)(1) of the Patent Act requires more than one component part of a multicomponent patented invention to be shipped abroad for assembly, no matter how important or critical that one component may be. Life Techs. Corp. v. Promega Corp.,(U.S. Feb. 22, 2017) 580 U.S. ___, slip opinion at *8 (No. 14-1538)… Writing for the Court, Justice Sotomayor rejected the case-specific approach of the Federal Circuit. The Supreme Court analyzed the ambiguous term “substantial” in the full context of the statute. Based on this context approach, the Court reasoned that “substantial” is best understood in a purely quantitative sense, as opposed to the qualitative importance of the component approach championed by Promega.