Atlantic Research Marketing Systems, Inc. v. Troy

Atlantic Research Marketing Systems, Inc. (Atlantic Research) (plaintiff) was a weapons manufacturer. Atlantic Research held a patent for a handguard device, which is a device that surrounds the barrel of a gun and allows ancillary devices to be safely attached to the gun. The specification for Atlantic Research’s patent, originally issued as patent ‘245, contained a written description for a sleeve-style handguard supported at two points on the gun: at the top of the gun and at the barrel nut. The patent claims on patent ‘245 were appropriately limited to the described handguard. However, when Atlantic Research applied for, and received, a reissue for patent ‘245, reissue patent ‘465, Atlantic Research added patent claims 31-36, which claimed protections for sleeve-style handguards with only one point of support: the barrel nut. Atlantic Research did not edit the patent specification on reissue. Stephen Troy (defendant) was a former employee of Atlantic Research. Troy developed and patented his own sleeve-style handguard. Troy’s handguard was supported only at one point: the barrel nut. Atlantic Research sued Troy for patent infringement, arguing that Troy’s handguard infringed on Atlantic Research’s reissue patent ‘465. Troy countered, arguing that claims 31-36 in Atlantic Research’s patent ‘465 were invalid because they exceeded the scope of the patent specification. The trial court granted Troy summary judgment, holding that claims 31-36 in Atlantic Research’s patent were invalid because the ‘465 patent’s specification only covered a handguard with two points of support. Atlantic Research appealed.