The PTAB has held that a supplier whose customer has been sued for patent infringement also has standing to petition for a CBM review. SAP America, Inc. v. Pi-Net Int'l, Inc., CBM 2013-13 (P.T.A.B. Sept. 19, 2013); Liberty Mutual Ins. Co. v. Progressive Casualty Ins. Co., CBM 2012-03 and CBM 2013-09. See also 157 Cong. Rec. S5432 (daily ed. Sept. 8, 2011) ("[A] company could seek a section 18 proceeding on the basis that customers of the petitioner had been sued for infringement.").
