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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.

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Holding and Reasoning (Lourie, J.)

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