Justia Patents Opinion Summaries

In 2000 the applicant obtained a patent for an âalternator pulleyâ that uses a one-way clutch to improve the power generation efficiency of an automobileâs alternator. Two years later, the applicant filed a reissue application to add a single dependent claim, narrower than the entire patent. The application was denied on the ground that the specified error was not subject to correction on reissue because the broadest scope of the patent would remain the same. The Board of Patent Appeals affirmed. The Federal Circuit reversed and remanded. Section 251, provides for reissue: "Whenever any patent is, through error without any deceptive intention, deemed wholly or partly inoperative or invalid, by reason of a defective specification or drawing, or by reason of the patentee claiming more or less than he had a right to claim in the patent." The section authorizes reissue to add the dependent claim; its omission could render a patent partially inoperative by failing to protect the disclosed invention to the fullest extent permitted by law.

McKesson holds a patent on an electronic means of communication between doctors and patients and sued Epic, which licenses software to medical providers, for infringement. The district court entered summary judgment for Epic. The Federal Circuit affirmed. McKesson failed to demonstrate that a single party directly infringes the patent and could not succeed on its claim of indirect infringement. Customers to whom Epic licenses software neither directly perform the âinitiating a communicationâ step nor exercise control or direction over another who performs this step; no single party infringes the entire method claimed by the patent. Expanding the rules governing direct infringement to reach independent conduct of multiple actors would subvert the statutory scheme for indirect infringement.

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.