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Keywords

patent
patentdeclaratory judgment

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Mas-Hamilton Group v. LaGard, Inc., 156 F.3d 1206, 48 U.S.P.Q.2d 1010

Facts

Competitor brought declaratory judgment action against patentee, seeking declaration that its electronic combination lock did not infringe patented lock and patentee counterclaimed for infringement.

Issue

Did the accused electronic combination lock infringe the patented lock, and was the patent invalid under the on-sale bar?

Did the accused electronic combination lock infringe the patented lock, and was the patent invalid under the on-sale bar?

Rule

To establish patent infringement, the patentee must demonstrate that the accused device contains every limitation of the asserted claims. The analysis involves determining the scope and meaning of the claims and comparing them to the accused device. A patent is presumed valid, and the burden of proving invalidity lies with the challenger. The on-sale bar applies if the invention was offered for sale more than one year before the patent application was filed.

To prove literal infringement of patent, the patentee must show that the accused device contains every limitation in the asserted claims; if even one limitation is missing or not met as claimed, there is no literal infringement.

Analysis

Conclusion

Affirmed.

Who won?

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