The Gentry Gallery, Inc. v. The Berkline Corp.
United States Court of Appeals for the Federal Circuit
134 F.3d 1473 (Fed. Cir. 1998)
Many sectional sofas are configured in an L-shape with a reclining seat at either end of the sofa. These reclining seats face different directions and often make it difficult for users to converse or watch a television program without shifting or moving. The Gentry Gallery (“Gentry”) (plaintiff) patented a unit of sectional sofa in which a console was placed between two independent reclining seats facing the same direction, known as the ‘244 patent. The console housed the controls for the reclining seats, eliminating the need to place each recliner at an exposed end of the sofa. In 1991, Gentry filed suit against The Berkline Corporation (“Berkline”) (defendant) alleging that it had infringed on the ‘244 patent by manufacturing and selling sectional sofas that also had two reclining seats facing the same direction, separated by a seat which had a back cushion that could be pivoted down and serve as a tabletop between the recliners. In the Berkline invention, the controls for the recliners were not placed within a console. The U.S. District Court for the District of Massachusetts granted Berkline’s motion for summary judgment of non-infringement, but denied its motions for summary judgment of invalidity and unenforceability, holding that the ‘244 patent was not invalid and thus enforceable. Berkline appealed.
Rule of Law
Holding and Reasoning (Lourie, J.)
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