Automotive Technologies International Inc. v. BMW of North America, Inc.
United States Court of Appeals for the Federal Circuit
501 F.3d 1274, 84 U.S.P.Q.2d 1108 (2007)
- Written by Samantha Arena, JD
Facts
Automotive Technologies International, Inc. (ATI) (plaintiff) was the assignee of a patent involving technology for a side-impact crash-sensing device for airbag deployment. The patent indicated that side-impact-sensing technology was a new field; the patent included five figures and a detailed explanation of a mechanical sensor assembly, which was described as the preferred type. The specification stated that electronic sensors could also be used, and a less detailed conceptual figure depicted an electronic sensor assembly. ATI brought an infringement suit against various automotive companies, including Delphi (defendant). Delphi moved for summary judgment, contending that the patent was invalid for lack of enablement because it provided an enabling disclosure only of mechanical side-impact sensors and not electronic sensors. ATI presented expert testimony that a person skilled in the art would know how to use existing electronic front-sensing technology to build an electronic side-impact sensor. The district court granted Delphi’s motion, finding that the patent did not enable the electronic sensor because making and using that type of sensor would require undue experimentation. ATI appealed.
Rule of Law
Issue
Holding and Reasoning (Lourie, J.)
What to do next…
Here's why 806,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.