KSR International Co. v. Teleflex, Inc.

Steven Engelgau obtained a patent for any automobile throttle pedal that combined three features: an adjustable position, an electronic sensor, and placement of the electronic sensor on a fixed point. When the patent was issued, all three features were prior art, meaning the information about each feature was already public knowledge. Teleflex, Inc. (plaintiff) was the exclusive licensee of Engelgau’s patent. KSR International (KSR) (defendant) owned a patent on an adjustable-position pedal. KSR added an electronic sensor to its patented pedal at a fixed point. Teleflex sued KSR for patent infringement. KSR claimed that Engelgau’s patent was invalid because the combination was obvious. The district court found that the combination was obvious because (1) all the elements were prior art and (2) the state of the industry made that combination inevitable. The district court granted summary judgment to KSR. The United States Court of Appeals for the Federal Circuit claimed that under the teaching, suggestion, or motivation (TSM) test, Engelgau’s patented combination was obvious only if the prior art had identified the specific problem that Engelgau’s combination solved. Because this specific requirement had not been met, the Federal Circuit found the combination was not obvious and vacated the judgment. The United States Supreme Court granted certiorari.