Richardson v. Stanley Works, Inc.
United States Court of Appeals for the Federal Circuit
597 F.3d 1288 (2010)
- Written by Jamie Milne, JD
Facts
David Richardson (plaintiff) held a design patent covering the design of a multifunction carpentry tool that combined a hammer, a stud-climbing tool, and a crowbar. Richardson’s tool was known as the Stepclaw. In 2005, Stanley Works, Inc. (Stanley) (defendant) began selling a multifunctional tool known as Fubar. Fubar was available in five versions, all of which were intended for carpentry and construction work. Richardson sued Stanley, alleging that the Fubar tools infringed Richardson’s design patent for the Stepclaw. The district court construed Richardson’s patent claims to distinguish the design’s ornamental elements from its functional elements. The court then held that, considering only the protected ornamental elements, an ordinary observer would not confuse the Fubar tools with Richardson’s patented Stepclaw design because the Fubar tools had a more rounded appearance and fewer blunt edges. Because the court concluded that the overall visual effect of the Fubar tools was not substantially similar to the Stepclaw, the court held that Stanley had not infringed Richardson’s patent. Richardson appealed.
Rule of Law
Issue
Holding and Reasoning (Lourie, J.)
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