Wednesday, November 13, 2013

The Gentry Gallery, Inc. v. The Berkline Corp. case brief

The Gentry Gallery, Inc. v. The Berkline Corp. case brief summary
134 F.3d 1473 (1998)


CASE SYNOPSIS
Plaintiff appealed from the United States District Court for the District of Massachusetts, which held that defendant did not infringe plaintiff's patent and declined to award attorney fees for plaintiff's defense. Defendant cross-appealed the decision that the patent was not shown to be invalid.

CASE FACTS
Plaintiff sued defendant alleging that defendant infringed its patent directed to a unit of a sectional sofa by manufacturing and selling similar sectional sofas.

DISCUSSION

  • On appeal, the court affirmed the trial court's holding that defendant did not infringe plaintiff's patent and the trial court's refusal to award attorney fees for the defense to defendant's assertion that the patent was unenforceable. 
  • The trial court correctly concluded that the claims were not infringed by defendant and the subject matter of the asserted claims was not shown to have been obvious. 
  • However, because the trial court clearly erred in finding that the written description portion of the specification supported certain of the broader claims asserted by plaintiff, the court reversed the decision that those claims were not invalid under 35 U.S.C.S. § 112.
CONCLUSION
The court affirmed the trial court's ruling that defendant did not infringe plaintiff's patent and the refusal to award attorney fees, but it reversed the trial court's findings that certain of plaintiff's broader claims were not invalid since the court clearly erred in finding that the written description portion of the specification supported those claims.


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