Best Lock v. Ilco Unican

94 F.3d 1563 (1996)

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Best Lock v. Ilco Unican

United States Court of Appeals for the Federal Circuit
94 F.3d 1563 (1996)

  • Written by Jody Stuart, JD

Facts

Best Lock Corporation (Best) (plaintiff) owned a design patent for a key blade, the portion of a key inserted into a lock’s keyway. Best also owned a design patent for the corresponding keyway. Ilco Unican (Ilco) (defendant) copied Best’s patented key-blade design, and Best sued Ilco in federal district court for patent infringement. The district court held that Best’s key-blade design patent was invalid, finding that the shape of the key blade was dictated by its function. Best appealed, asserting that although a particular key and its corresponding lock must match to operate the lock, an unlimited number of key-blade and corresponding keyway designs were available. Therefore, Best argued, the key blade could have many different shapes and was not dictated solely by function. The parties did not dispute that the key blade at issue must be designed as shown in the patent in order to perform its intended function, fitting into its corresponding lock’s keyway.

Rule of Law

Issue

Holding and Reasoning (Lourie, J.)

Dissent (Newman, J.)

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