Wednesday, November 13, 2013

Regents of the University of California v. Eli Lilly & Co. case brief

Regents of the University of California v. Eli Lilly & Co. case brief summary
119 F.3d 1559 (1997)


CASE SYNOPSIS
Plaintiff appealed a judgment of the United States District Court for the Southern District of Indiana, which found in favor of defendant in plaintiff's patent infringement suit.

CASE FACTS
Plaintiff received two patents relating to the manufacture of insulin. Plaintiff later sued defendant, claiming defendant's insulin manufacturing process infringed upon plaintiff's patents. Defendant argued it had not infringed upon either of plaintiff's patents, that the asserted claims made regarding one of plaintiff's patents were invalid, and that both patents were unenforceable.


DISCUSSION

  • The court held trial court had jurisdiction over the claim because theEleventh Amendment did not protect state institutions acting as plaintiffs. 
  • The court upheld the trial court's ruling that specific claims regarding one patent were invalid because they did not adequately describe the new material. 
  • The court then held defendant did not infringe upon plaintiff's other patent as the process defendant used was sufficiently different from plaintiff's patent. 
  • Finally, the court held that both of plaintiff's patents were enforceable because evidence of plaintiff's allegedly inequitable conduct in obtaining patents was immaterial.

CONCLUSION
The court affirmed the judgment as to the invalidity of specific claims in one of plaintiff's patents due to insufficient descriptions in the claims. The court reversed the judgment as to the enforceability of patents, as evidence relied upon in declaring patents unenforceable was immaterial.

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