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Keywords

statuteappealpatentnovation
discoverystatutepatentcorporationrespondent

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Halliburton Oil Well Cementing Co. v. Walker, 329 U.S. 1, 67 S.Ct. 6, 91 L.Ed. 3, 71 U.S.P.Q. 175

Facts

Cranford P. Walker and others, doing business as Depthograph Company, filed a patent infringement action against Halliburton Oil Well Cementing Company, claiming that Halliburton infringed on certain claims of Walker's patent for an apparatus designed to measure the location of obstructions in oil wells. The district court ruled in favor of Walker, affirming the validity and infringement of the claims. Halliburton's subsequent appeals were denied, leading to a review by the Supreme Court.

Cranford P. Walker, owner of Patent No. 2,156,519, and the other respondents, licensees under the patent, brought this suit in a federal district court alleging that petitioner, Halliburton Oil Well Cementing Company, had infringed certain of the claims of the Walker patent.

Issue

Whether the claims held valid by the lower courts failed to provide the 'full, clear, concise, and exact' description of the alleged invention as required by statute.

Whether the claims held valid by the lower courts failed to provide the 'full, clear, concise, and exact' description of the alleged invention as required by statute.

Rule

Before any inventor or discoverer shall receive a patent for his invention or discovery he shall make application therefor, in writing, to the Commissioner of Patents, and shall file in the Patent Office a written description of the same, and of the manner and process of making, constructing, compounding, and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art or science to which it appertains, or with which it is most nearly connected, to make, construct, compound, and use the same; and in case of a machine, he shall explain the principle thereof, and the best mode in which he has contemplated applying that principle, so as to distinguish it from other inventions; and he shall particularly point out and distinctly claim the part, improvement, or combination which he claims as his invention or discovery. * * *

Analysis

The court analyzed whether Walker's claims sufficiently described the invention, particularly the tuned acoustical resonator, in terms of its physical characteristics and its relationship to the existing Lehr and Wyatt machine. The court found that the claims described the resonator's function rather than its structure, failing to meet the statutory requirements for patent claims.

We must, however, determine whether, as petitioner charges, the claims here held valid run afoul of Rev.Stat. s 4888 because they do not describe the invention but use 'conveniently functional language at the exact point of novelty.' General Electric Co. v. Wabash Appliance Corporation supra, 304 U.S. at page 371, 58 S.Ct. at page 903, 82 L.Ed. 1402.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the patent claims were invalid due to insufficient description as mandated by patent law.

Reversed.

Who won?

The prevailing party in this case was Halliburton Oil Well Cementing Company. The Supreme Court reversed the lower court's ruling, determining that the patent claims held by Walker were invalid for not meeting the statutory requirements of clarity and specificity in describing the invention. The court emphasized the importance of a clear description in patent law to prevent overly broad claims that could hinder innovation.

The prevailing party in this case was Halliburton Oil Well Cementing Company. The Supreme Court reversed the lower court's ruling, determining that the patent claims held by Walker were invalid for not meeting the statutory requirements of clarity and specificity in describing the invention.

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