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Potts v. Coe

United States Court of Appeals for the District of Columbia
145 F.2d 27 (1944)


Lewis M. Potts (plaintiff) sued the commissioner of patents, Conway P. Coe (defendant), to obtain a patent for an invention developed by Potts' company. Potts lost his case in federal district court and appealed to the United States Court of Appeals for the District of Columbia. The appellate court dismissed the appeal because Potts failed to meet the higher burden of proof required when a corporation, not an individual, invents a device. The court took judicial notice that the reason for the higher burden was a congressional finding that patent law is intended to encourage individual innovation, and that corporations suppress innovation by spending more on research than individuals can afford. Potts challenged the judicial notice and moved to vacate the dismissal of his appeal.

Rule of Law


Holding and Reasoning (Arnold, J.)

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