Cuno Inc. v. Pall Corporation
United States District Court for the Eastern District of New York
729 F. Supp. 234 (1989)
- Written by Elliot Stern, JD
Facts
Cuno Inc. (plaintiff) and Pall Corporation (defendant) were both manufacturers of microporous nylon membrane filters and major competitors in the market for these filters. In September 1986, Cuno sued Pall in the United States (US) for infringement of Cuno’s patents. One issue in the case was whether a US patent Pall had received was valid. While the US case was pending, Pall sued Cuno in the United Kingdom (UK) Court of Chancery, Patent Division, on grounds that Cuno infringed Pall’s European Patent Office (EPO) patent. Pall’s EPO patent was a counterpart patent to Pall’s US patent that was under consideration in the US case. Pall’s US and EPO patents described the same technological invention. The UK court found that Pall’s EPO patent was valid. The judge in the case made extensive findings and construed critical terms in the claims made in Pall’s EPO patent. Following the UK judgment, Pall asked the US court to apply collateral estoppel with regard to the factual findings made in the UK court and grant partial summary judgment on that basis. Pall argued that collateral estoppel was appropriate because the EPO patent described the same technology and made materially identical claims to Pall’s US patent under consideration in the case.
Rule of Law
Issue
Holding and Reasoning (Weinstein, J.)
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