Trenton Industries v. A. E. Peterson Manufacturing Co.
United States District Court for the Southern District of California
165 F.Supp. 523 (1958)
John Adler developed a high chair that was easier to fold and ship than other high chairs due to a signature attachment feature. Adler did not invent the attachment feature, which had been publicly disclosed in earlier patents. Adler shared his high chair with Haugh, who gave a specimen chair to Peterson, the owner of A. E. Peterson Manufacturing Company (Peterson Co.) (defendant). Haugh offered to negotiate a royalty agreement that would allow Peterson to manufacture the chair. Peterson scrutinized the chair for two months, then returned the chair and declined to manufacture it. Peterson then placed a chair on the market that was similar to Adler’s chair, without compensating Adler for use of the chair’s design. Subsequently, Trenton Industries (Trenton) (plaintiff), a company controlled by Adler, obtained a patent for Adler’s chair. The patent application was a combination-patent claim, which specified the elements that comprised the chair rather than the characteristics that made the chair novel. Trenton sued Peterson Co. for patent infringement and for compensation in quasi-contract for using the chair during the period preceding the patent. As a defense, Peterson Co. claimed that (1) the patent was invalid and (2) there was no infringement because Peterson had based his design on church chairs that he felt free to use in good faith.
Rule of Law
Holding and Reasoning (Holtzoff, J.)
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