Amini Innovation Corp. v. Anthony California, Inc.
United States Court of Appeals for the Federal Circuit
439 F.3d 1365 (2006)
- Written by Mike Cicero , JD
Facts
Amini Innovation Corp. (Amini) (plaintiff), a seller of bedroom furniture, held copyright registrations for carved ornamental woodwork incorporated into several bedroom-furniture items. Amini also owned a US design patent (the design patent) for a design of a bed frame. Anthony California, Inc. (Anthony) (defendant) likewise sold bedroom furniture. Amini contacted James Chang, Anthony’s president, to communicate Amini’s belief that Anthony was infringing both Amini’s copyrights and the design patent. Anthony disagreed with Amini’s position and refused to stop selling its accused products. Amini then sued Anthony in the United States District Court for the Central District of California, asserting six counts of copyright infringement and one count of design-patent infringement. During discovery, Amini adduced some evidence that Chang had attended trade shows at which Amini displayed its copyrighted designs. Following the completion of discovery, Anthony moved for a summary judgment of noninfringement as to all counts. Regarding the copyright counts, the district court held that the elements of each copyrighted work were not original and that the elements’ overall selection and arrangement was likewise not original. Regarding the design-patent count, the district court observed that Anthony’s accused bed frame lacked four orbs and bed posts appearing in the claimed design. The district court therefore granted Anthony’s summary-judgment motion in its entirety. Amini appealed.
Rule of Law
Issue
Holding and Reasoning (Rader, J.)
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