Lockwood v. American Airlines, Inc.
United States Court of Appeals for the Federal Circuit
107 F.3d 1565 (1997)
- Written by Mike Cicero , JD
Facts
Lawrence B. Lockwood (plaintiff) owned three patents directed to an interactive sales system that, via terminals, allowed salespersons to make sales presentations to customers while also allowing customers to place orders for goods and services. Claim 1 from one of Lockwood’s patents recited: “A system for automatically dispensing information, goods, and services . . . comprising . . . at least one customer sales and information terminal [that included] audio-visual means for interaction with a customer . . . .” Lockwood sued American Airlines, Inc. (American) (defendant) in the United States District Court for the Southern District of California, alleging that American’s SABREvision reservation system infringed all three of his patents. That reservation system improved upon American’s original reservation system, called SABRE, which American had developed in the 1960s. American asserted a patent-invalidity defense, contending that Lockwood’s asserted claims were obvious under 35 U.S.C. § 103 over a combination of the SABRE system with a prior-art patent. The district court agreed, granting a summary judgment of invalidity and noninfringement as to all three of Lockwood’s patents. Lockwood appealed and argued that the SABRE system did not qualify as prior art because its details were not publicly known.
Rule of Law
Issue
Holding and Reasoning (Lourie, J.)
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