Sundstrand Brief (Robins)

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Sundstrand Brief- Honeywell v. Sundstrand The foundation of this case is solely rooted in whether the doctrine of equivalence applies between the APS 3200 developed by Sundstrand and a Honeywell patent on variable inlet guide vane systems. After the following analysis, I am sure the Court will agree that the Doctrine of Equivalence does not apply in the case and no infringement occurred.

In this case, Sundstrand is held to an obvious double standard in which Honeywell outlines conflicting arguments. We begin with Honeywell’s patent for its inlet guide vane airflow system. The claims which were supposedly infringed upon were initially dependent upon previous claims in the patent. As Honeywell knew that it could not prove infringement on the previous claims, it attempted to make the claims independent through amendment, thus narrowing the specific claims. So, Honeywell tried to narrow its claims to legitimize the patent.

Now, however, Honeywell admits that there is no literal infringement of its claims, it says there is a broad one and cites the Doctrine of Equivalence as reason for infringement. They maintain that the “set point” device is essentially equivalent to the DELPQP system developed in the APS 3200, even though the results of these processes are very different. They argue that the “set point” system is a broad claim including the DELPQP.

Now, the contradiction arises. In order to convince the court of the infringement of an independent claim, Honeywell narrowed its patent’s focus. However, once approved by the court, they claim that infringement can be considered on a broad range of devices through the Doctrine of Equivalence. If Honeywell wanted their claim to apply to the APS 3200, they should have initially written the claim correctly, one that did not need amendments to prove infringement. Agreeing with Honeywell sets a precedent that patent claims can be amended in order to prove infringement and the Doctrine of Equivalence then used as a tool to prove infringement. This is contrary to the point of the patent system itself. The amendment to the patent should be overturned and any infringement claim dropped. If the change is upheld, then only literal infringement should warrant damages, something that both sides have agreed is not present in this case.

Lastly, these two inventions also do not fall under the necessary prerequisites in the Doctrine of Equivalence, which states that the machines musta accomplish essentially the same thing. On analysis of the inventions, the outputs and results of the inventions are completely different even if they act in a similar manner. Different outcomes mean they do not accomplish the same thing. This also presents further evidence against infringment.