Bottom Line Management, Inc. v. Pan Man, Inc.
United States Court of Appeals for the Federal Circuit
228 F.3d 1352 (2000)
Bottom Line Management, Inc. (plaintiff), manufactured nonstick plates called “platens” designed to fit the upper half of two-sided-burger-cooking devices in fast-food restaurants. Bottom Lines’ patented platens had studs welded to the back instead of bolts mounted through them, creating a seamless cooking surface that facilitated uniform Teflon coating. The patent itself provided that the platens could be removed and refurbished. Pan Man, Inc. (defendant), refurbished and sold used platens by replacing the old Teflon coating and straightening or welding on new studs that customers bent or broke off when removing the platens from the cookers. Bottom Line sued Pan Man for patent infringement, arguing that Pan Man’s refurbishment of the platens amounted to reconstruction of Bottom Line’s patented product instead of permissible repair. The trial court granted Pan Man summary judgment, reasoning that its refurbishment constituted permissible repairs, not reconstruction. Bottom Line appealed.
Rule of Law
Holding and Reasoning (Friedman, J.)
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