Cybor Corp. v. FAS Technologies, Inc. case brief summary
138 F.3d 1448 (1998)
CASE FACTS
Plaintiff brought suit against defendants for a declaratory judgment of non-infringement of defendants' patent. The devices in question were used to dispense small volumes of liquid onto semiconductor wafers.
PROCEDURAL HISTORY
At trial, a jury found that plaintiff literally infringed defendants' patent. The trial court denied plaintiff's motion for judgment as a matter of law and defendants' motion for an exceptional case award of attorney's fees. Both parties appealed.
DISCUSSION
CONCLUSION
The court affirmed the orders of denial because the trial court properly instructed the jury as to whether plaintiff's device was structurally and functionally equivalent to defendants'; since evidence of plaintiff's willfulness was weak, the case was not exceptional under the patent law.
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138 F.3d 1448 (1998)
CASE SYNOPSIS
The parties sought review of the orders
of the United States District Court for the Northern District of
California which denied plaintiff's motion for judgment as a matter
of law on its non-infringement claims and defendants' motion for an
exceptional case award under 35 U.S.C.S. § 285.CASE FACTS
Plaintiff brought suit against defendants for a declaratory judgment of non-infringement of defendants' patent. The devices in question were used to dispense small volumes of liquid onto semiconductor wafers.
PROCEDURAL HISTORY
At trial, a jury found that plaintiff literally infringed defendants' patent. The trial court denied plaintiff's motion for judgment as a matter of law and defendants' motion for an exceptional case award of attorney's fees. Both parties appealed.
DISCUSSION
- On appeal, the court reviewed the issue of claim construction de novo.
- The court determined that the trial court properly narrowed the scope of the claim language and instructed the jury to determine whether plaintiff's device was structurally and functionally equivalent to defendants'.
- The court determined that the case was not exceptional because the evidence of willful infringement was weak and plaintiff acted in good faith.
CONCLUSION
The court affirmed the orders of denial because the trial court properly instructed the jury as to whether plaintiff's device was structurally and functionally equivalent to defendants'; since evidence of plaintiff's willfulness was weak, the case was not exceptional under the patent law.
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