elements of contributory and induced infringement". In addition, the district court stated the initial notice of patent infringement was not sufficient to establish Netgear's knowledge of infringtement. The district court denied the summary of motion for infringement and granted Netgear's summary of motion for non-infringement. Judgment by the Court of Appeals for the Federal Circuit The federal court of appeals referenced to determine contributory infringement. Specifically, the patent owner must show: "1) that there is direct infringement, 2) that the accused infringer had knowledge of the patent, 3) that the component has no substantial non-infringing uses, and 4) that the component is a material part of the invention". To determine direct infringement, the court stated "if an accused product operates in accordance with a standard, then comparing the claims to that standard is the same as comparing the claims to the accused product"; however, the court softend their statement with the following "We acknowledge, however, that in many instances, an industry standard does not provide the level of specificity required to establish that practicing that standard would always result in infringement". However, Netgear's customer service records that had recommended end-users enable fragmentation on four models (WPN111, WG511, WPN824, and WG311T) was accepted as a viable evidence. The appeal court, thus, agreed with the district court that Philips failed to establish a genuine issue of material fact regarding direct infringement for all but the four models with corresponding customer service records. The court decided Philip's notices of infringement provided Netgear sufficient knowledge of infringement. Likewise, the court could not find substantial non-infringing uses of wireless fragmentation. When considering material part of invention, the district court claimed defragmentation did not infringe US patent 4,975,952 as it only made material claims of fragmentation techniques. Weighing all four elements of direct infringement, the federal court reversed the district court's summary judgment for non-infringement Netgear's models WPN111, WG511, WPN824, and WG311T. In addition, the federal court overruled the district court's limitation on damages. allows limited damages when a patent holder uses their claimed invention without clearly marking the product with the relevant patent number. The federal court held the district court was in error as does not apply to any patent directed a method and US patent 4,975,952 explicitly claimed a method for fragmentation. Analysis of the Courts on US patent 642 Patent claim analysis (Clarification of the terms used in claim) The second patent