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Sandt Technology v. Resco Metal and Plastics

264 F.3d 1344 (2001)

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Sandt Technology v. Resco Metal and Plastics

United States Court of Appeals for the Federal Circuit
264 F.3d 1344 (2001)

Facts

In 1996, Sandt Technology, Ltd. (Sandt) (plaintiff) obtained a patent for a cover made to secure the housing of pay telephones. Resco Metal and Plastics Corporation and Seven Oceans Enterprises, Inc. (collectively, Resco) (defendant) began marketing a similar product in 1997. Sandt brought a patent-infringement action in federal district court and sought a declaratory judgment of patent validity. Resco moved for summary judgment, arguing that Sandt’s patent was invalid. Resco’s president, Frederick Zausner, testified that he had built the security cover in 1990—before the filing date of Sandt’s patent—and unsuccessfully applied for patent protection in 1991. Zausner included the rejected patent application as evidence. Resco also presented witness testimony. The court granted Resco’s motion. Sandt appealed to the United States Court of Appeals for the Federal Circuit.

Rule of Law

Issue

Holding and Reasoning (Michel, J.)

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