Pfaff v. Wells Electronics (901422128)

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Read for 2/23/11

Reading Notes

  • Decided by the USSC in 1998
  • In early 1981 Pfaff designed a new computer chip socket with detailed drawings
    • Also showed a sketch to representatives at TI who placed an order before the critical date
  • Had not made a prototype before the offers to sell
    • Applied April 19. 1982 and had first reduced to practice the summer before
  • District court said the claims were infringed and the patent was valid
    • CAFC said the one year period began with the offer to sell so the patent was invalid
  • USSC holds the patent is invalid based on the on-sale bar
    • Had to decide if the commercial offering was enough even before reduction to practice
  • CAFC had the view of "substantially complete at the time of sale"
    • If it has been described suffiently as to allow those skilled in the matter to understand and produce the invention
  • Reject Pfaff's argument that precedent and the interest in giving inventors a clear onset of the 1-year bar justifies a different interpretation of "invention"
    • USSC agrees with this however does not think it requires a reduction to practice element - an invention can be complete before it is reduced to practice
  • Cite Bonito Boats and Elizabeth
  • Two condition for on-sale bar are fulfilled in this instance

Statutory Bars

  • Meaning of "invention" in Patent Act is the inventor's conception
    • Doesn't need to be reduced to practice to receive a patent
  • Two conditions of the on-sale bar
    1. The product must be the subject of a commercial offer for sale
    2. The invention must be ready for patenting
  • Underlying policy is to prevent the inventor from removing existing knowledge from public
  • Act of 1836 was first to expressly include an on-sale bar

==Class Notes