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In re Icon Health & Fitness, Inc.
United States Court of Appeals for the Federal Circuit
496 F.3d 1374 (2007)
Icon Health & Fitness, Inc. (Icon) (plaintiff) applied for a patent disclosing a foldable treadmill capable of being stored upright. The patent claims disclosed a gas spring connecting the base and upright component, allowing the treadmill to remain stable in the upright position. The patent examiner rejected Icon’s patent, finding the claims obvious under 35 U.S.C. § 103 based on two prior art references: (1) the Damark advertisement, which described a folding treadmill; and (2) the Teague patent, which described a bed capable of folding up into a cabinet. The Damark advertisement anticipated each of Icon’s claims except for the gas spring component. The Teague patent demonstrated a dual-action spring providing support and stability for the folding bed in both the open and closed positions. Icon appealed the examiner’s decision, contending that the Teague patent did not constitute analogous prior art for purposes of an obviousness analysis. The Board of Patent Appeals and Interferences (Board) affirmed the rejection, finding that both Teague’s and Icon’s patents were directed to the purpose of maintaining a folding mechanism in a stable position, and Teague’s patent thus properly constituted analogous art. Icon appealed.
Rule of Law
Holding and Reasoning (Prost, J.)
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