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On July 3, the Westlaw Journal of Intellectual Property featured comments by Michele Van Patten Frank about the 7-2 decision, where the Court held that Section 271(f)(2) of the Patent Act allows extraterritorial recovery if infringing components are supplied from within U.S. borders.

Ms. Frank said, "Other countries could see the decision as an opportunity for U.S. patent holders to expand into foreign markets, and they could retaliate. It is not often a Supreme Court patent law decision has the potential to exacerbate international trade dispute tensions."