Law360, New York ( July 27, 2015, 10:28 AM EDT) -- In the most recent decision in Akamai Technologies Inc. v. Limelight Networks Inc., the long-running case that has now seen three opinions from the Federal Circuit and one from the U.S. Supreme Court, the Federal Circuit reaffirmed its commitment to the single-entity rule — the rule that infringement of a method claim requires that a single actor perform every step of the claim.[1] The Federal Circuit, however, also articulated three circumstances in which a defendant may be vicariously liable for the actions of another: (1) an agency relationship, (2) a contract to perform some of the acts amounting to infringement, and (3) a joint enterprise. Thus, while it is undoubtedly true that Akamai, as well as its predecessors, have made it difficult for patentees to prove infringement in multiple-actor scenarios, and correspondingly easy for defendants to avoid infringement, the Federal Circuit has seemingly left a window of opportunity for patentees....