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Space Systems/Loral, Inc. v. Lockheed Martin Corp.
United States Court of Appeals for the Federal Circuit
271 F.3d 1076, 60 USPQ2d 1861 (2001)
Dr. Fred Chan was an employee of Ford Aerospace and Communications Corp. (Ford), a predecessor to Space Systems/Loral, Inc. (SSL) (defendant). Chan developed a novel method for correcting a satellite’s position after it has been pulled out of proper orientation by gravitational forces or solar winds. Chan’s method was called the prebias technique. In March 1982, Ford sent a proposal describing Chan’s prebias technique to a French aerospace company. The proposal included rough drawings and a cost estimate. Chan had yet to develop an engineering model to test his technique and was unsure whether his idea would in fact work. After several more months of development, on April 21, 1983, Ford applied for a patent for the prebias technique. Later, Lockheed Martin Corp. (Lockheed) (plaintiff) sued SSL. Lockheed argued that Ford’s patent for the prebias technique was invalid under patent law’s on-sale bar because Chan’s invention was allegedly ready for patenting and offered for sale more than one year before Ford applied for the invention’s patent. The district court agreed, finding that Ford’s patent for the prebias satellite-adjustment technique was invalid and granting summary judgment for Lockheed. SSL appealed.
Rule of Law
Holding and Reasoning (Newman, J.)
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