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Keywords

statuteappealmotionsummary judgmentpatentcorporationmotion for summary judgment
statuteappealmotionsummary judgmentpatentcorporationmotion for summary judgment

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Cooper Cameron Corp. v. Kvaerner Oilfield Products, Inc., 291 F.3d 1317, 62 U.S.P.Q.2d 1846

Facts

In a patent infringement suit, Cooper Cameron Corporation sued Kvaerner Oilfield Products, Inc. for infringement of its patents related to subsea wellheads. The district court granted Kvaerner's motion for summary judgment of noninfringement of Cooper's U.S. Patent 5,544,707 and ruled that Cooper's U.S. Patent 6,039,119 was invalid for inadequate written description. Cooper appealed the decision, arguing that the court erred in its findings regarding both patents.

In a patent infringement suit, Cooper Cameron Corporation sued Kvaerner Oilfield Products, Inc. for infringement of its patents related to subsea wellheads. The district court granted Kvaerner's motion for summary judgment of noninfringement of Cooper's U.S. Patent 5,544,707 and ruled that Cooper's U.S. Patent 6,039,119 was invalid for inadequate written description. Cooper appealed the decision, arguing that the court erred in its findings regarding both patents.

Issue

Whether the district court erred in granting summary judgment of noninfringement and invalidity of the patents.

Whether the district court erred in granting summary judgment of noninfringement and invalidity of the patents.

Rule

A determination of infringement, whether literal or under the doctrine of equivalents, is a question of fact. Patent infringement under the doctrine of equivalents may be limited by the all-limitations rule. Whether patent claims are properly supported by the written description is also a question of fact.

A determination of infringement, whether literal or under the doctrine of equivalents, is a question of fact. Patent infringement under the doctrine of equivalents may be limited by the all-limitations rule. Whether patent claims are properly supported by the written description is also a question of fact.

Analysis

The court found that Cooper was foreclosed from asserting infringement under the doctrine of equivalents due to the all-limitations rule, as Kvaerner's device did not meet the specific claim limitation of the workover port being 'between the two plugs.' However, the court erred in ruling that the '119 patent claims were invalid for lack of written description, as the drawings provided adequate support for the claims. Additionally, there was a genuine issue of material fact regarding whether certain reports were 'printed publications' under the statute governing conditions of patentability.

The court found that Cooper was foreclosed from asserting infringement under the doctrine of equivalents due to the all-limitations rule, as Kvaerner's device did not meet the specific claim limitation of the workover port being 'between the two plugs.' However, the court erred in ruling that the '119 patent claims were invalid for lack of written description, as the drawings provided adequate support for the claims. Additionally, there was a genuine issue of material fact regarding whether certain reports were 'printed publications' under the statute governing conditions of patentability.

Conclusion

The court affirmed the noninfringement ruling for the '707 patent but reversed the invalidity ruling for the '119 patent and the determination regarding the SISL reports.

The court affirmed the noninfringement ruling for the '707 patent but reversed the invalidity ruling for the '119 patent and the determination regarding the SISL reports.

Who won?

Kvaerner Oilfield Products, Inc. prevailed on the issue of noninfringement of the '707 patent, as the court found that the accused device did not meet the specific claim limitations. However, Cooper Cameron Corporation prevailed on the issue of the '119 patent's validity, as the court determined that the drawings provided sufficient written description support for the claims.

Kvaerner Oilfield Products, Inc. prevailed on the issue of noninfringement of the '707 patent, as the court found that the accused device did not meet the specific claim limitations. However, Cooper Cameron Corporation prevailed on the issue of the '119 patent's validity, as the court determined that the drawings provided sufficient written description support for the claims.

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