Hybritech Inc. v. Monoclonal Antibodies Inc.
United States Court of Appeals for the Federal Circuit
802 F.2d 1367 (1986)
- Written by Eric Miller, JD
Facts
In 1975, two researchers published a groundbreaking article describing a method for producing monoclonal antibodies. The research made it easier for scientists to conduct immunoassays—a type of diagnostic test for detecting antigens in bodily fluids—because immunoassays required the use of large amounts of antibodies. Hybritech Inc. (plaintiff) secured a patent on testing kits for immunoassays using monoclonal antibodies. A few years later, the kits were released on the market and enjoyed substantial success. Hybritech brought suit against Monoclonal Antibodies Inc. (defendant) for patent infringement. The district court held that the Hybritech patent was invalid on the ground of obviousness. In reaching this conclusion, the court discounted the commercial success of Hybritech’s kits, which the court attributed to the business and marketing acumen of Hybritech’s staff. The court gave much greater weight to the increased availability of antibodies following the 1975 article. Hybritech appealed to the United States Court of Appeals for the Federal Circuit.
Rule of Law
Issue
Holding and Reasoning (Rich, J.)
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