Innovention Toys, LLC v. MGA Entertainment, Inc.
United States Court of Appeals for the Federal Circuit
637 F.3d 1314 (2011)
Innovention Toys, LLC (Innovention) (plaintiff) created and obtained a patent for a chess-like, strategy-based board game that incorporated refracted light beam “lasers” into the game play. MGA Entertainment, Inc. (MGA) (defendant) created a similar chess-like, strategy-based board game. Innovention brought a patent infringement suit against MGA in the United States District Court for the Eastern District of Louisiana. MGA filed a countersuit, claiming that Innovention’s patent was invalid on obviousness grounds. MGA based its claim of obviousness on Laser Chess, a prior, chess-like computer-strategy game that incorporated virtual lasers into game play. The Innovention patent and a published article on the Laser Chess game described each game’s components, rules, and ultimate objective. The district court found that Laser Chess did not qualify as analogous art for purposes of an obviousness analysis, because it was an electronic version of Innovention’s patent for a physical game. The district court granted Innovention summary judgment. MGA appealed.
Rule of Law
Holding and Reasoning (Lourie, J.)
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