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Keywords

appealpatent
depositionpatent

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Applied Materials, Inc. v. Advanced Semiconductor Materials America, Inc., 98 F.3d 1563, 40 U.S.P.Q.2d 1481

Facts

Applied Materials, Inc. brought an action against Advanced Semiconductor Materials America, Inc. (ASM) for patent infringement related to semiconductor integrated circuits. The United States District Court for the Northern District of California upheld the validity of Applied Materials' '609 patent while ruling that ASM's process did not literally infringe the '389 patent but was found to infringe under the doctrine of equivalents. ASM appealed the decision, contesting the validity of the '609 patent on grounds of double patenting and obviousness, as well as the infringement ruling regarding the '389 patent.

Both Applied Materials and ASM are manufacturers and sellers of devices used in the production of semiconductor integrated circuits by chemical vapor deposition (CVD). The inventions of the patents in suit are directed to improvements in the methods and apparatus of CVD for the purposes of reducing or eliminating contaminants and enhancing the quality of the deposition product.

Issue

Whether the '609 patent is invalid for double patenting or obviousness, and whether ASM's process infringes the '389 patent under the doctrine of equivalents.

Whether the '609 patent is invalid for double patenting or obviousness, and whether ASM's process infringes the '389 patent under the doctrine of equivalents.

Rule

The rule against double patenting prevents an inventor from extending the term of exclusivity by patenting variations that are not patentably distinct from the first invention. A patent is presumed valid unless proven otherwise by clear and convincing evidence. The doctrine of equivalents allows for infringement findings even if the accused process does not literally meet the patent claims, provided it is substantially the same.

Analysis

Conclusion

The court affirmed the validity of the '609 patent, reversed the finding of infringement under the doctrine of equivalents for the '389 patent, and upheld the invalidity of the '313 patent.

We affirm the decisions that the '609 patent is valid and that the '389 patent is not literally infringed, reverse the decision that the '389 patent is infringed under the doctrine of equivalents, and affirm the decision that the '313 patent is invalid.

Who won?

Applied Materials prevailed in part, as the court upheld the validity of its '609 patent and ruled that ASM's process did not infringe the '389 patent under the doctrine of equivalents. The court's reasoning emphasized the importance of the presumption of validity for patents and the failure of ASM to provide clear and convincing evidence to support its claims of invalidity.

Applied Materials prevailed in part, as the court upheld the validity of its '609 patent and ruled that ASM's process did not infringe the '389 patent under the doctrine of equivalents.

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