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Evans Cooling Systems, Inc. v. General Motors Corp.
United States Court of Appeals for the Federal Circuit
125 F.3d 1448 (1997)
In 1984, John Evans invented a cooling system for use in internal combustion engines. In 1989, Evans demonstrated the system to General Motors Corporation (GM) (defendant). During the demonstration, GM gave Evans reason to believe that GM intended to steal the invention. In 1991, GM and its independent dealers offered the invention for sale through the introduction of the 1992 Corvette, which contained an LT1 engine with reverse flow engine cooling. GM sent its independent dealers instructions for ordering the Corvette and received over 2,000 orders. One order was placed by an independent dealer in June 1991, based on a sales contract between the dealer and retail customer Aram Najarian for a Corvette with an LT1 engine. Evans filed a patent application for the cooling system on July 1, 1992. In 1994, Evans Cooling Systems, Inc. and Patent Enforcement Fund, Inc. (collectively, Evans) (plaintiff) brought a patent infringement suit against GM. GM moved for summary judgment, contending the patent was invalid under the 35 U.S.C. §102(b) on sale bar because GM and its independent dealers offered the invention for sale before July 1, 1991. The district court granted the motion. Evans appealed.
Rule of Law
Holding and Reasoning (Michel, J.)
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