In 2007, Teleflex, Inc. sued KSR international claiming that one of KSR's products infringed Teleflex's patent on connecting an adjustable vehicle control pedal to an electronic throttle control. KSR argued that the combination of the two elements was obvious, and the claim was therefore not patentable.
The district court ruled in favor of KSR, but the Court of Appeals for the Federal Circuit reversed it in January 2005. The case then went to the U.S. Supreme Court, where it unanimously reversed the judgment of the Federal Circuit in 2007. It held that the disputed claim 4 of the patent was obvious under the requirements of 35 U.S.C. 103 and that in rejecting the District Court's rulings, the Court of Appeals analyzed the issue in a narrow, rigid manner inconsistent with 103 and the precedents'.
When generally describing the obviousness test, the Court was largely controversial:
In determining whether the subject matter of a patent claim is obvious, neither the particular motivation nor the avowed purpose of the patentee controls. What matters is the objective reach of the claim. If the claim extends to what is obvious, it is invalid under §103. One of the ways in which a patent's subject matter can be proved obvious is by noting that there existed at the time of invention a known problem for which there was an obvious solution encompassed by the patent's claims.The contested patent was Patent No. 6, 237, 565 B1, entitled "Adjustable Pedal Assembly With Electronic Throttle Control". Claim 4 of the patent describes a mechanism for combining an electronic sensor with an adjustable automobile pedal so the pedal's position can be transmitted to a computer that controls the throttle in the vehicle's engine. When Teleflex accused ksr of infringing on this patent by adding an electronic sensor to one of KSR's previously designed pedals, KSR countered that claim 4 was invalid because its subject matter was obvious.
Hi Shauray,
ReplyDeletegood job. I find it interesting how many times the Federal Circuit disagrees with the district court rulings on whether a design is obvious or not. Then the Supreme Court reverse Federal Circuit's decision. What is your opinion? Do you think an adjustable pedal is an obvious patent? Would love to hear your thoughts.
Hi Shauray,
ReplyDeleteI found your blog to be very informative and easy to read. In particular, it was helpful to have the quote of the Court ruling in order to understand the rationale for ruling in terms of the obviousness component. It was helpful to have your description of Claim 4 where you describe the combination of the electric sensor to the throttle--which appears to be the critical obvious component which KSR deemed obvious. Thanks for a great read!
Hi Shauray,
ReplyDeleteGreat blog post! I enjoyed getting your perspective of the KSR vs. Teleflex case, as professor went over it in class as well. It was to get the full overview of the case, as it helped me to truly understand the overall case. I think it was very helpful to have the description of the claim that you looked into. Once again, great post!