The Federal Circuit’s recent decision in Wi-LAN Inc. v. Sharp Electronics Corp. demonstrates potential difficulties for plaintiffs in proving infringement where third-party information is necessary to establish that defendants practice the asserted claims. The court affirmed the district court’s grant of summary judgment of noninfringement, holding that purported printouts of source code and supporting declarations obtained from third-party chip manufacturers were inadmissible hearsay. Although the court does not explicitly identify what type of information regarding the source code would have been admissible, it identified several problems with the specific printouts presented by Wi-LAN that prevented them from falling within exceptions to the hearsay rule.