AT-IP REPORT

February 13, 2003

Electronic Newsletter of the Intellectual Property Committee

Section of Antitrust Law

American Bar Association

 

We are pleased to bring you “The Use of Article 82 to Compel a Compulsory Patent License: Intel v. Via Technologies Takes Magill/IMS One Step Further” by Frank Fine.  Mr. Fine is a Partner with DLA Brussels, was lead counsel to NDC in the Brussels proceedings described in the article and presently represents NDC in the appeal by IMS to the Court of First Instance in that NDC Health/IMS Health matter.

 

On December 20, 2002, the English Court of Appeal reversed the summary dismissal of certain defenses asserted by Via Technologies under Articles 81 and 82 of the Treaty Establishing the European Community (“EC Treaty”).  The decision by the Vice Chancellor was joined by Lord Justice Mummery and Lord Justice Tuckey and is available at

http://www.courtservice.gov.uk/judgmentsfiles/j1483/intel_v_via_technologies.htm.

 

After noting that the “the ingredients of computer technology, patent infringement and Articles 81 and 82 EC Treaty make a somewhat indigestible dish,” the Vice Chancellor concludes by stating and then answering in the affirmative two simple questions: “Are the defences under Articles 81 and 82 ones for which Via has real prospects of success?  Are there other compelling reasons why these defences should only be disposed of at a trial?” (para. 89)

 

Lord Justice Mummery’s concurring opinion notes: “My provisional view at this stage of the litigation is that the defence under Article 82 is stronger than that under Article 81 and that there are serious difficulties in the way of either of the competition defences eventually succeeding at trial.  But it is too soon to have sufficient confidence in the ultimate outcome to decide summarily that the defences have no real prospect of success.” (para. 96)

 

In the United States, of course, the legal standards of section 2 of the Sherman Act may not coincide with those under Article 82 of the EC Treaty, but alleged monopolists’ refusals to deal and conditional refusals to deal with respect to exclusive intellectual property rights continue to be the subject of litigation and debate.  For a relatively current point-counterpoint discussion of the topic under US law see articles by Jonathan Gleklen and Jeffrey MacKie-Mason in the July 2002 edition of Antitrust Source: http://www.abanet.org/antitrust/source/july.html

 

In his recent speech before the American Intellectual Property Law Association, Acting Assistant Attorney General for the Antitrust Division R. Hewitt Pate noted continuing debate on the subject and commented that:

 

Even outside the intellectual property context, the monopolist's general right unilaterally to refuse to deal is a fundamental and well-recognized part of antitrust law.  Likewise, the right not to license is a fundamental aspect of patent law.  Using antitrust to permit subjective inquiry into the intellectual property holder's motivations for refusing to deal cuts at the very heart of the intellectual property right -- the right to exclude.

 

That speech is available at: http://www.usdoj.gov/atr/public/speeches/200701.htm.

 

The issue continues to be examined on both sides of the Atlantic Ocean.

 

This article was edited with the assistance of John Martin and Christopher Forstner of Hunton and Williams.  Joseph Kattan provided some additional observations.

 

Anthony Chavez
Vice Chair-Electronic Communication
Intellectual Property Committee
J.Anthony.Chavez@ExxonMobil.com

 

Ed Biester
Co-Coordinator-Electronic Communication
egbiester@duanemorris.com


The Use of Article 82 to Compel a Compulsory  Patent License: Intel v. Via Technologies Takes Magill/IMS One Step Further.

By Frank Fine*

Background

U.S. antitrust lawyers may have difficulty grasping the peculiarities of the European Union's divisions between "federal" and "Member State" authority, particularly as the EU is not a federal government as such with the powers that one would normally associate with a sovereign power.  The current political turmoil among Member States over "European" policy on Iraq underscores the gap between the EU's aspirations to achieve genuine sovereign powers and current reality.  The frictions between federal and state power within the EU are no more apparent than on issues of property ownership.  Article 295 of the EC Treaty, which is also referred to as the Treaty Establishing the European Community,[1] states that the Treaty "shall in no way prejudice the rules in Member States governing the system of property ownership."[2]  This provision of the EC Treaty had the effect of placing under the umbrella of "States' rights" not only the national system of intellectual property protection, but also determinations of specific IP ownership within said system.  However, the European Court of Justice held in its 1966 Consten and Grundig judgment that Article 222 (now Article 295) of the EC Treaty does “not exclude any influence whatever of Community law on the exercise of national property rights.”[3]  Indeed, as the Court recognized, the exercise of national property rights may be counter to other Community interests, such as Article 30 of the EC Treaty (free movement of goods), as well as Article 82 of the of the EC Treaty.[4]

 

In 1968, the European Court of Justice in Parke, Davis declared that the exercise of IP rights is not an unlimited right and can itself be abusive: "Although a patent confers on its holder a special protection at national level,” it does not follow that the exercise of patent rights would be entitled to protection if “the use of the patent were to degenerate into an abuse of the abovementioned protection.”[5]

 

These cases form the essential background of the Magill case,[6] which was decided by the European Court of Justice in 1995 over the rather stunning issue of whether several UK broadcasters were entitled to exercise their statutory copyrights in their daily program listings, effectively, to prevent anyone, but here, Irish publisher Magill, from putting on the UK market the kind of weekly, multi-channel TV guide which had been on the market for years on the continent.  Despite the obvious consumer interest in breaking this bottleneck, the Court approached the Article 295 issue in a circumspect manner, stating that in "exceptional circumstances," Article 82 applied to the mere refusal to license an IP right.[7]

 

Exceptional circumstances were found in Magill, where the broadcasters' abusive conduct prevented the emergence of "new" product on the market, although the significance of the novelty introduced by Magill was itself downplayed by the Court.[8]  Some legal commentators went so far as to argue that the Magill Court required a finding of two markets, even though there is nothing in Magill which suggested that the application of Article 82 to an IP right required market leveraging.    Indeed, this view presupposed that the daily TV listings, which were routinely given away to newspapers for reprinting, constituted the dominated market of the broadcasters from which they were leveraging into a "secondary” market in weekly TV magazines.  In fact, there was only one relevant market, and this was the market in weekly TV magazines.

 

The EC Courts subsequently confirmed in both Ladbroke[9] and Bronner[10] that a monopolist's prevented emergence of a new product was not necessary for the assertion of Article 82 to compel access to an essential facility under exceptional circumstances.  What really mattered was whether the IP holder, by refusing to license, was preventing access to an essential facility.  As the Court of First Instance (“CFI”) stated in Ladbroke, which involved the question of whether broadcasts of French horse races could be compulsorily licensed pursuant to Article 82, it was sufficient for the applicant to show that the exercise of copyright (by refusal to license) deprived the applicant of a product or service that was “essential for the exercise of the activity in question.”[11]  The European Court of Justice in Bronner added that the refusal to license (if not discriminatory) must be likely to eliminate all competition on the relevant market.[12]  There was no indication from Ladbroke or Bronner that market leveraging was required.

 

Some legal commentators read Ladbroke and Bronner as a judicial retreat from the precedent set in Magill, as neither the CFI nor the European Court, respectively, found that the applicants for a license had established an infringement of Article 82.  However, the facts in Ladbroke and Bronner were hardly supportive of an infringement of Article 82, even on a broad reading of Magill.  In Ladbroke, it was clear to the CFI that broadcasts of French horse races were not essential to the betting organization, Ladbroke, where bets were placed prior to any broadcast of the race in question.  In Bronner, it was obvious to the European Court that Mr. Bronner was a free rider--there were no technical, legal or financial barriers preventing him from establishing his own home-delivery scheme.  Unfortunately, the CFI's and European Court's valuable interpretation of Magill was overlooked.[13]

 

NDC Health/IMS Health

 

Magill, Ladbroke, and Bronner paved the way for the Commission's interim decision in NDC Health/IMS Health.[14]  Whereas the EC Courts in Ladbroke and Bronner were confronted with weak factual situations which did not permit the application of their broad interpretation of Article 82, the European Commission found a compelling situation: IMS claimed an exclusive copyright in an industry standard, the 1860 brick structure,[15] which was relied upon by German pharmaceutical manufacturers for the supply of regional pharmaceutical sales reports, and refused to license the right to use this brick structure, which was in database form, to its competitors, NDC and AzyX.  IMS was already in the relevant market for regional sales reports, and NDC sought to compete in this very market.  The Commission, in summarizing the case precedents noted above, confirmed that under Magill, the application of Article 82 to a refusal to license, when access by competitors was essential, did not require that the dominant firm prevent the emergence of a new product, but rather, that its refusal of access was likely to eliminate all competition on the relevant market.[16]  Nor was it necessary, in the Commission's view, for NDC to prove that IMS was engaged in market leveraging.[17]  It was sufficient that IMS impeded NDC from competing on the one relevant market, that of regional sales reports.[18]

 

The IMS decision – subject to its ultimate outcome on appeal and with the caveat per footnote 14 that its result has been suspended pending appeal – has greatly clarified the test, under Article 82, for obtaining a compulsory license.  Although the decision confirms that antitrust concerns may prevail over IP rights in extreme situations, the Commission has yet to grant a compulsory license where the subject matter is complex or sophisticated, or where the asserted IP right is pursuant to a patent.  However, Article 82 is "directly applicable" in the national courts of the Member States, so it was foreseeable that such a court would eventually take the Magill doctrine one important step further.

 

Intel v. Via Technologies

On December 20, 2002, the English Court of Appeal reversed the summary dismissal of certain "Euro defenses" in the Intel Corporation/Via Technologies litigation. [19]  While it was held that the validity of such defenses will ultimately be determined at trial, this decision may assist defendants in raising such defenses in intellectual property litigation.

The facts

Both Intel and Via make central processing units and chipsets for use in personal computers.  As part of the factual background, the decision notes that Intel is the “largest designer and maker of x86 CPUs in the world, accounting for about 80% of sales for each year between 1996 and 2000 (both inclusive),” for “the years 1996 to 1998 (both inclusive) its Chipsets accounted for about 100% of the market” and “[b]etween 1998 and 2000, its share of the world-wide market in Chipsets declined to about 75%” while Via had 19% of the remaining 25%.[20]

 

By cross-license, Intel licensed Via the right to use Intel patented technology to manufacture chips and Intel was granted a right to use certain Via technology.  Via was restricted to using the Intel technology in non-Pentium IV products.  In September 2001, Intel brought two actions in the Patents Court, situated in the English Chancery Division (part of the English High Court), alleging that Via was infringing five of Intel's patents.  In its defense and counterclaim, Via denied the validity of each of the patents relied on and denied that it had infringed any valid claim in any of them.  In addition, Via raised defenses under Articles 81 and 82 of the EC Treaty and the corresponding provisions of the UK Competition Act of 1998, i.e. that Intel's infringement claim was an unlawful attempt to compel Via to enter into a licensing agreement, containing cross-licenses for Via's technology an other restrictions, which was contrary to Article 81(1) of the EC Treaty and Section 2(1) of the UK Competition Act of 1998, and Intel's refusal to grant a patent license on reasonable terms or at all was an abuse of dominant position pursuant to Article 82 of the EC Treaty and Section 18 of the Act.[21]  Intel succeeded in obtaining summary judgment for patent infringement against Via.  Via appealed.

The issues

Although permission to appeal had only been granted in respect of one of the competition issues, the issues argued before the English Court of Appeals were as follows:

·        Whether (and if so, when) the owner of an intellectual property right who is in a dominant position for the purposes of Article 82 is obliged not to exercise that right so as to exclude others from the market or a substantial part of the market.

·        Whether the owner of an intellectual property right (whether dominant or not) may lawfully exercise his right to license it on terms which either distort competition or are wider than necessary to define the extent to which his exclusive right has been surrendered.

·        Whether it is a defense to an action for infringement of a patent that its enforcement would enable the owner of the patent to act in breach of Articles 81 or 82.

The Court of Appeal's decision

The Court of Appeal reversed the judgment of Justice Lawrence Collins of the Chancery Division, Patents Court, noting that cases involving Articles 81 and 82 often raised questions of mixed law and fact which were unsuitable for summary determination.[22]

The Court of Appeal held that it was possible to defend a patent infringement claim by contending that the enforcement of the patent would enable the holder of the patent to act in breach of Articles 81 or 82.[23]   Secondly, it held that Via had a prospect of success in two defense arguments, namely that (i) Intel's refusal to grant a patent license on reasonable terms, or at all, was an abuse of its dominant position under Article 82; and (ii) Intel's infringement claim was an unlawful attempt to compel Via to enter into a cross-license for Via technology and other restrictions contrary to Article 81(1).

As regards the Article 82 defense, the Court of Appeal considered the decisions in Volvo v Veng,[24] Magill, Ladbroke, and Bronner.[25]  Counsel for Intel had contended that these cases showed “that there can only be exceptional circumstances within the Magill test if all the conditions in either Magill or IMS are satisfied” and that “the result of the refusal must be to exclude an entirely new product from the market (Magill) or all competition to the patentee (IMS).”[26]

 

The Court of Appeal rejected Intel's argument, stating firstly, that Magill and IMS did not indicate all circumstances which might be deemed "exceptional" for the purposes of determining the applicability of Article 82 to the exercise of an IP right; and secondly, that as the President of the Court of First Instance suggested in his interim order of October 26, 2001 in the IMS case,[27] a breach of Article 82 was possible without the exclusion of a new product or all competition.[28]   The Court therefore held that  in both the Chipset Action and the CPU Action, Via pleaded facts “which may give rise to the abuse by the owner of an intellectual property right of his dominant position contrary to Article 82.”[29]

 

Intel has not appealed to the House of Lords and the case will now proceed to trial on the merits.

The implications

The judgment affirms the Commission's reading of the Magill and Bronner judgments as they were interpreted in the IMS decision of July 2001.  The Court of Appeal even suggested that the Commission had interpreted Bronner too narrowly in the IMS case when it held that all competition in the relevant market had to be eliminated for there to be the "exceptional circumstances" required to show an abuse of dominance.  Instead, it may only be necessary for competition to be excluded from the person requesting access to the facility (i.e. the applicant for a compulsory license) as opposed to all of the licensor's competitors.[30]

However, there is another interesting ramification of the Intel judgment.  It will be recalled that the CFI President, in suspending the Commission's interim decision in the IMS case, concluded, inter alia, that IMS had reasonable grounds for asserting that Magill-Bronner were capable of an interpretation other than the one advanced by the Commission.  Consequently, in his view, the Commission failed to establish, on legal grounds, a prima facie case that IMS had committed an Article 82 infringement.  This would not seem to square with the conclusion of the English Court of Appeal that Via Technology posed a legally viable defense on the basis of the European Commission's interpretation of Magill-Bronner.

The December 11, 2002 ruling of the District Court of Rotterdam in the De Telegraaf case ("Dutch Magill"),[31] in which the Commission's view of the EC Court precedents in IMS was also affirmed, now seems to present a real schism between the CFI, on the one hand, and the EC Commission and the UK and Dutch courts, on the other, as to the application of Article 82 to the refusal to license intellectual property rights.  These differences should be resolved by the European Court of Justice when it gives judgment on the preliminary reference from the Frankfurt Regional Court in one of the NDC/IMS copyright infringement cases pending in Germany.

In blessing the application of the essential facilities doctrine to valuable intellectual property rights, whether in the form of patents or copyright, the Court of Appeal has laid down the gauntlet to the European Commission.  If the Commission is truly sincere in applying Article 82 to refusals to license essential facility-IP rights in order to break IP-created or enhanced monopolies, then it will need to show that owners of complex, sophisticated IP rights will not, by virtue of their investment, invention or cunning be excluded from the application of this enforcement policy.

 

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Mr. Fine is a Partner, DLA Brussels, was lead counsel to NDC in the Brussels proceedings described in the article and presently represents NDC in the appeal by IMS to the Court of First Instance.  He can be contacted by email at Frank.Fine@dla.com or at 32-2-629-6973.

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AT-IP Report is the electronic Newsletter of the Intellectual Property Committee of the American Bar Association, Section of Antitrust Law.  The views expressed in the AT-IP Report are the authors' only and not necessarily those of the ABA, the Section of Antitrust Law or the Intellectual Property Committee.  If you wish to comment on the content of this Electronic Newsletter, please write to the ABA, Section of Antitrust Law, Attention: Intellectual Property Committee, 750 North Lake Shore Drive, Chicago, Illinois 60611.  Copyright 2003 American Bar Association.



*Partner, DLA Brussels.  The author was lead counsel to NDC in the Brussels proceedings described herein and presently represents NDC in the appeal by IMS to the Court of First Instance.

 

 .[1] The Treaty establishing the European Economic Community (EEC) was signed in Rome on March 25, 1957, and entered into force on January 1, 1958.  As the Treaty of Rome was amended, including amendments upon the accession of new Member States, consolidated versions of what was then usually referred to as the "EC Treaty" were periodically published.  The Amsterdam Treaty, which was effective May 1, 1999, renumbered the Articles of the EC Treaty.  Articles 85 and 86 of the Treaty of Rome, the EU counterparts of sections 1 and 2 of the Sherman Act, were renumbered as Articles 81 and 82 of the EC Treaty.  The EC Treaty is also referred to as the Treaty Establishing the European Community.  A consolidated version the Treaty Establishing the European Community, as amended by the Amsterdam Treaty, 1997 O.J. (C340) 145-175, is available at http://europa.eu.int/eur-lex/en/treaties/dat/ec_cons_treaty_en.pdf.  The Treaty on European Union, which was signed in Maastricht, The Netherlands, on February 7, 1992, and entered into force on November 1,1993, created the political union among the Member States.  A consolidated version of the Treaty on European Union, as amended by the Amsterdam Treaty, 1997 O.J. (C340) 175-308, is available at http://europa.eu.int/eur-lex/en/treaties/dat/eu_cons_treaty_en.pdf.  The Treaty Establishing the European Community and the Treaty on European Union were last amended by the Treaty of Nice 2001 O.J. (C80/01).  The Treaty of Nice, signed on February 26, 2001, entered into force on February 1, 2003.  Under the Treaty of Nice, the former Treaty of European Union and the Treaty Establishing the European Community have been merged into one consolidated version, 2002 O.J. (C325) 1-184, which is available at http://europa.eu.int/eur-lex/en/dat/2002/c_325/c_32520021224en00010184.pdf.

For background see discussion of European Treaties available at http://europa.eu.int/abc/treaties_en.htm.

 

[2] This broad wording does not suggest or imply that the Member States' delegation of power to harmonize certain forms of IP protection at EU-level, for example, software and databases, or multilateral arrangements aimed at achieving a level playing field, as in TRIPS, are infringements of Article 295.

 

[3] Case 56 & 58/64  [1966] ECR 299, at page 345 (emphasis added).  Decisions by European Commission are now appealable to the Court of First Instance, which was established in 1989, rather than directly to the European Court of Justice.  However, judgments of the European Court of First Instance may be appealed to the European Court of Justice.

 

[4] Article 82.  Any abuse by one or more undertakings of a dominant position within the common market or in a substantial part of it shall be prohibited as incompatible with the common market in so far as it may affect trade between Member States.

Such abuse may, in particular, consist in:

(a) directly or indirectly imposing unfair purchase or selling prices or other unfair trading conditions;

(b) limiting production, markets or technical development to the prejudice of consumers;

(c) applying dissimilar conditions to equivalent transactions with other trading parties, thereby placing them at a competitive disadvantage;

(d) making the conclusion of contracts subject to acceptance by the other parties of supplementary obligations which, by their nature or according to commercial usage, have no connection with the subject of such contracts.

 

[5] Case 24/67 [1968] ECR 55, at page 72 (emphasis added).

 

[6] Magill TV Guide, O.J. L 78/43 (1989); affirmed in RTE v. Commission, Case T-69/89 [1991] ECR II-485; BBC v. Commission, Case T-70/89 [1991] ECR II-535; ITP v. Commission, Case T-76/89 [1991] ECR II-575.  The judgments against RTE and ITP were both affirmed on appeal in RTE and ITP v. Commission, Cases C-241-242/91P [1995] ECR I-743.

 

[7] See [1995] ECR I-743, at paras. 50-56.

 

[8] As a factual matter, the broadcasters were already on the UK market with own-channel weekly TV guides and these were deemed to be within the same product market as the multi-channel guide introduced by Magill.

 

[9] Tierce Ladbroke v.  Commission, Case T-504/93 [1997] ECR II-923.

 

[10] Bronner v.  Mediaprint, Case C-7/97 [1998] ECR I-7791.  Although Bronner involved the issue of whether compulsory access could be obtained to a newspaper's home delivery system, rather than to its intellectual property, the European Court assumed that if the Magill test of exceptional circumstances applied to "the exercise of any property right whatsoever. . .[,]" the applicant needed to show that the "service in itself be indispensable to carrying on that person's business, inasmuch as there is no actual or potential substitute in existence for that home-delivery scheme."  See para. 41.  In borrowing this language from Ladbroke, the European Court finally confirmed that introduction of a "new" product is not a prerequisite for the application of Article 82 to a refusal to license.

 

[11] Ladbroke, supra, at para. 131.

 

[12] Bronner, supra, at para. 40.

 

[13] In the EC jurisprudential world, the value of Ladbroke and Bronner as precedents was not diminished by the fact that, in the view of those two EC courts, the requirements for a compulsory license were not satisfied in those two cases.

 

[14] NDC Health/IMS Health, O.J. L 59/18 (2002).  An "interim decision" is an urgent remedy akin to a preliminary injunction, and is based on a prima facie showing of infringement, coupled with the complainant's suffering of serious and irreparable harm and a balancing of interests.  The IMS decision, now the subject matter of an appeal by IMS to the Court of First Instance, was subsequently suspended by an ex parte order of the President of the Court of First Instance in IMS Health v. Commission (Case T-184/01R [2002] ECR II-2349), then suspended by the same judge following a hearing of both parties (Case T-184/01R2 [2002] ECR 2002).  The President of the Court affirmed the latter order in NDC Health Corp. v. IMS Health Inc. (Case C-481-01P(R)1 [2002] ECR 3193).  In parallel copyright litigation before the Frankfurt trial court ("Landgericht"), the latter court suspended main proceedings against NDC pending a preliminary ruling from the European Court on issues of both copyright and the applicability of Article 82 in IMS Health GmbH v. NDC Health GmbH, Case C-418/01.

 

[15] This brick structure consisted of 1860 geographic segments of the territory of Germany, which was formed by allocating a number of German postal codes to a particular segment, or "brick."

[16] NDC Health/IMS Health, supra, at paras. 68-70.

 

[17] Id., at paras. 183-84.

 

[18] Id., at paras. 183-85.

 

[19] Case Nos:  A3/2002/1380; A3/2002/1381, a copy of which available at http://www.courtservice.gov.uk/judgmentsfiles/j1483/intel_v_via_technologies.htm.

 

[20]  Para. 8.

 

[21] See paras. 15-26.

 

[22] See paras. 51, 89, 96, 97.

 

[23] Id.

 

[24] [1988] ECR 6211.

 

[26] See paras. 39-51.

 

[26] Para. 47.

 

[27] See fn 14 supra.

 

[28] Para. 48.

 

[29] Para. 49- 51.

 

[30] Strictly speaking, the essential facilities doctrine is not even necessary in a case of discriminatory refusal to license; so here, the Court of Appeal may have overshot his faithful reliance on EC precedent.

 

[31] Cases MEDED 01/2430-RIP; MEDED 01/2474-RIP.  This case involved, ironically, the refusal of several Dutch broadcasters to license coyright TV listings to the Dutch newspaper, de Telegraaf.