Motionless Keyboard Co. v. Microsoft Corp.
United States Court of Appeals for the Federal Circuit
486 F.3d 1376 (2007)
Thomas Gambaro invented a handheld keyboard requiring only small finger movements to trigger the keys. Gambaro developed various prototype models of the keyboard, including the Cherry Model 5. Gambaro secured a business partner to garner funding to further develop and patent the keyboard technology. In 1987, Gambaro provided visual presentations, but not actual demonstrations, of the Cherry Model 5 to various investors with whom he entered into non-disclosure agreements (NDAs). The NDAs expired in 1989. In June 1990, Gambaro disclosed the Cherry Model 5 to Sheila Lanier for the purpose of conducting a typing test, which ultimately took place on July 25, 1990, and involved the connection of the device to a computer to transmit typed data. Lanier signed a NDA the same day. Gambaro applied for two patents for the mechanisms of the keyboard on June 6, 1991 and January 11, 1993, and assigned the patents to Motionless Keyboard Co. (MKC) (plaintiff). MKC brought suit against Microsoft, Nokia, and Saitek (defendants) claiming infringement of the patents. The defendants moved for summary judgment, contending that the patents were invalid under the 35 U.S.C. § 102(b) “public use” bar. The district court granted the motion. MKC appealed.
Rule of Law
Holding and Reasoning (Rader, J.)
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