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appealsummary judgmentpatentcorporation
appealtrialsummary judgmentpatent

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Evans Cooling Systems, Inc. v. General Motors Corp., 125 F.3d 1448, 155 A.L.R. Fed. 645, 44 U.S.P.Q.2d 1037

Facts

Evans Cooling Systems, Inc. held a patent for a cooling system for internal combustion engines. The company alleged that General Motors Corporation (GM) infringed this patent by selling vehicles equipped with the patented technology. GM countered that the patent was invalid due to the 'on-sale' bar, asserting that the patented invention was offered for sale prior to the critical date. The district court granted summary judgment in favor of GM, leading to Evans' appeal.

Evans asserted before the trial court that GM should not be allowed to invalidate the '636 patent because GM, in fact, stole the invention from Evans.

Issue

Whether the patent was invalid under the statutory on-sale bar due to an offer for sale made prior to the critical date.

Whether the invention was placed on sale prior to critical date, such that patent is invalid under statutory on-sale bar, is ultimately conclusion of law that Court of Appeals reviews de novo, although it is based on underlying facts.

Rule

Analysis

The court found that the order placed by a consumer for a vehicle containing the patented cooling system constituted an offer for sale that invalidated the patent under the on-sale bar. The evidence showed that GM and its dealers had placed orders for the vehicle before the critical date, meeting the criteria for the on-sale bar. The court also noted that the alleged misappropriation of the invention by GM did not create an exception to the on-sale bar.

The district court granted summary judgment in favor of GM on September 30, 1996, because the record established that GM and its dealers placed the 1992 Corvette with the LT1 engine on sale prior to the critical date.

Conclusion

The court affirmed the district court's ruling that the patent was invalid due to the pre-critical date offer for sale.

Who won?

General Motors Corporation prevailed in this case because the court found that the patent held by Evans Cooling Systems was invalid under the statutory on-sale bar. The court determined that the evidence clearly demonstrated that GM and its dealers had placed the patented invention on sale prior to the critical date, thus invalidating the patent. The court also rejected Evans' argument for an exception to the on-sale bar based on alleged misappropriation, emphasizing that the independent dealers acted innocently in their transactions.

The trial court's decision is therefore affirmed.

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