Akamai, part II: Cross-border problems, or Who Remembers Blackberries?

No, not that kind.

Richmond School of Law Professor Osenga raises an interesting issue with respect to the recent oral arguments at the Supreme Court in the Limelight v Akamai case (see links here).  
In Limelight the Federal Circuit suggested below that direct infringement by a single actor is not required to prove inducement.  So, what happens if a step of the method is performed outside the US?  Professor Osenga is worried.

Direct infringement is based on domestic behavior and only domestic behavior. It asks, does the alleged infringer make, use, sell, or offer to sell the patented invention in the United States? If any of the steps of a method occur outside of the United States, there is no direct infringement. Before the Federal Circuit’s decision, if there was be no direct infringement of a patent, there could also be no indirect infringement. After the [Federal Circuit's Limelight v Akamai] decision, however, because there is no requirement of direct infringement, liability for indirect infringement of a United States patent can be based on behavior that occurs outside of the United States.

This was exactly the scenario back in the NTP v RIM case, decided back in 2005.  You may remember, in that case, the Federal Circuit upheld the district court's finding that RIM directly infringed NTP's claims, despite the fact that part of RIM's accused system was located in Canada.   The basis for that decision was that the "control and beneficial use" of the system was in the U.S., despite the extraterritorial location of a critical part of the accused system.  

So what am I missing here?