Crown Packaging Tech., Inc. v. Ball Metal Beverage Container Corp.

The companies sell the parts of beverage cans. Crown sued Ball concerning two patents issued to Crown in 2005. The district court entered summary judgment for Ball. The Federal Circuit reversed and remanded, first holding that the patents did not violate the written description requirement. The common specification of the patents conveyed, to one of ordinary skill in the art, that Crown was in possession of an embodiment that improved metal usage. There remained a material issue of fact as to whether the patents claimed improvements inherently anticipated by a prior patent application, so summary judgment was inappropriate.