Woodland Trust v. Flowertree Nursery, Inc. case brief

Woodland Trust v. Flowertree Nursery, Inc. case brief summary
148 F.3d 1368 (1998)

CASE SYNOPSIS

Plaintiff patent holders brought an action against defendant nursery corporation to enforce its patent on an invention that protected foliage plants from freezing. The United States District Court for the Middle District of Florida held the patent invalid based on prior knowledge and use by others under 35 U.S.C.S. § 102(a). The patent holders challenged the judgment.

CASE FACTS
The patent holders alleged a violation of their patent on an invention for protecting a plot of foliage plants from freezing, which established an insulating covering of ice over ground level watering. The nursery corporation offered oral testimony from several interested witnesses that the nursery corporation had used the invention in their plant nursery for many years prior to the patent but had discontinued use of the process prior to its patent. The district court found that the patent was invalid under 35 U.S.C.S. § 102(a) because of prior knowledge and use by others.

DISCUSSION

• On appeal, the court ruled that the patent was not invalid. 
• The court ruled that the oral evidence, standing alone, did not provide the clear and convincing evidence necessary to invalidate the patent on the ground of prior knowledge and use under § 102(a).

CONCLUSION

The court reversed the judgment from the district court that held the patent invalid and remanded for further proceedings.

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