Summary judgments of noninfringement are always worth noting when they come out because they give insight into how attorneys effectively persuade judges that a determination that is usually fact-intensive still doesn't raise triable factual disputes.
This was the case in Perdiemco, LLC. v. Geotab, 2:15cv727 in which Judge Rodney Gilstrap recently concluded that the plaintiff had not raised a triable issue with respect to two asserted claims because it had not shown that particular steps are met by the defendant's use of the accused system. The crucial analysis came when the plaintiff argued that its contentions were sufficient to satisfy the test for divided infringement. The case wasn't analogous to the circumstances considered by the Federal Circuit in Akamai, and while that decision did hold that "other factual situations may arise" that warrant attributing others' performance of method steps to a single actor, the Court concluded that this was not one of those scenarios.
The Court noted that as there wasn't a factual dispute as to what happens in the relevant scenario, just the legal one of whether that could constitute infringement, and thus summary judgment was the appropriate tool to resolve it.