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Rite-Hite Corporation v. Kelley Company, Inc.
United States Court of Appeals for the Federal Circuit
56 F.3d 1538 (1995)
Rite-Hite Corporation (Rite-Hite) (plaintiff) was issued a patent (the ‘847 patent) for a device used to secure vehicles to loading docks during loading and unloading. Subsequently, Rite-Hite brought a claim of patent infringement against Kelley Company, Inc. (Kelley) (defendant), a competitor in the market for vehicle-loading restraints. After separating the issue of liability from the assessment of damages, the district court found that Kelley had infringed the ‘847 patent. During the damages portion of the trial, Rite-Hite sought profits for lost sales based on two of Rite-Hite’s vehicle restraints, one that incorporated the ‘847 patent and one that did not, which was called the ADL-100. Rite-Hite also claimed damages for lost sales of dock levelers, which were devices that covered the gaps between a dock and a loading vehicle. The district court awarded damages to Rite-Hite that included the lost profits of both the vehicle restraints and the dock levelers that were packaged with the restraints. Kelley appealed the decision to award damages for lost sales of the ADL-100 and any damages for the packaged dock levelers.
Rule of Law
Holding and Reasoning (Lourie, J.)
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