Chef America, Inc. v. Lamb-Weston, Inc.
United States Court of Appeals for the Federal Circuit
358 F.3d 1371 (2004)
- Written by Eric Miller, JD
Facts
Chef America, Inc. (plaintiff) held a patent on a process for baking dough with a light, flaky texture. The language of the patent’s claims called for the dough to be heated to a temperature between 400 degrees and 850 degrees Fahrenheit. The temperature range was added after the United States Patent and Trademark Office examiner initially rejected the claims for being non-enabling. Chef America brought an infringement action against Lamb-Weston, Inc. (defendant) in federal district court. Lamb-Weston moved for summary judgment of noninfringement. The court granted the motion, finding that Chef America’s patent required the dough itself to be heated to a temperature between 400 and 850 degrees—a temperature at which the dough would be burned to a crisp—as opposed to heating the oven to a temperature in that range. Chef America appealed to the United States Court of Appeals for the Federal Circuit.
Rule of Law
Issue
Holding and Reasoning (Friedman, J.)
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