Case Overview: KSR vs Teleflex
In KSR International vs Teleflex, KSR International, an engineering, design, and manufacturing firm, was sued by Teleflex, a billion dollar medical device company, in a patent infringement case regarding "an electronic sensor that was added to an existing pedal design". This case set the precedent for further cases of obviousness as its ruling was central to this issue.
Case Details:
In this dispute, Teleflex's maintained rights to the exclusive license of a patent for "Adjustable Pedal Assembly with Electronic Throttle Control." in particular, a claim included "adding an electronic sensor to the pedal which then transmitted information to the computer's controlling the engine's throttle". KSR argued that adding the sensor to the pedal was simply an obvious act.
Decision:
This decision was controversial as issues of obviousness and prior art came in to play. As one article cited judge Kennedy, who stated that "In order to determine the obviousness of a patent claim, the courts must consider prior art, the differences between the prior art and the subject matter of the claim, and the ordinary skill level required of a person in the subject matter". The case was originally ruled in KSR's favor--then reversed by the Court of Appeals--and then ultimately reversed by the Federal Circuit. Their ruling was based on the fact that claim four was obvious.
Future Implications:
Using obviousness as a valid argument against a claim began to become more commonplace after KSR International vs Teleflex. Further cases such as Leapfrog Enterprises Inc v Fisher Price as well as Perfect Web Technologies vs UnfoUSA began to utilize obviousness in their arguments. It is clear that this case set a precedent for analyzing obviousness in patent claims.
Sources:
[1] http://www.casebriefs.com/blog/law/patent-law/patent-law-keyed-to-adelman/nonobviousness/ksr-international-co-v-teleflex-inc/
Hi Siddharth,
ReplyDeleteI really found this post to be helpful. The way you organized it makes it very easy for the reader to follow and understand. I think it's really important to point out future implications for this case (as you did). Recognizing the prededent and weight that this case holds in the IP world (specifically concerning obviousness) is crucial. I'd be curious as to whether or not obviousness was informally considered in IP litigation before this case (and other paramount cases) set a formal precedent for discussing obviousness. Obviousness is something that seems so, well, obvious. It doesn't seem like you'd need to formally set principles that allow for discussion.