Pfaff v. Wells Electronics (901422128)

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

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