Automotive Technologies International Inc. v. BMW of North America, Inc.
United States Court of Appeals for the Federal Circuit
501 F.3d 1274 (2007)
Automotive Technologies International Inc. (ATI) (plaintiff) owned a patent for devices that detect side-impact crashes to vehicles. These devices would trigger the deployment of an airbag if a vehicle was involved in a side collision. The claim portion of ATI’s patent claimed the invention of a side-impact sensor that is triggered by changes in velocity. The specification portion of the patent included diagrams and descriptions for both a mechanical switch and an electronic switch for the velocity-type sensor. The specification’s diagram and descriptions for the mechanical switch were very detailed, but those for the electronic switch were minimal. ATI sued BMW of North America, Inc. and other companies in the automotive industry (defendants) for patent infringement. The defendants argued that the only structure in the patent’s specification supporting ATI’s patent’s claim was the mechanical-switch assembly. The district court disagreed with the defendants, finding that the patent’s specification contained both a mechanical-switch assembly and an electronic-switch assembly to support the patent’s claim. However, the district court then found the patent’s claim for the electronic-switch assembly was invalid because it did not meet the enablement requirement. ATI appealed.
Rule of Law
Holding and Reasoning (Lourie, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 176,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 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.