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.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.