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Valmont Industries, Inc. v. Reinke Manufacturing Co.

983 F.2d 1039, 25 U.S.P.Q.2d 1451 (1993)

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Valmont Industries, Inc. v. Reinke Manufacturing Co.

United States Court of Appeals for the Federal Circuit
983 F.2d 1039, 25 U.S.P.Q.2d 1451 (1993)

Facts

Valmont Industries, Inc. (Valmont) (plaintiff) held a patent on a self-propelled irrigation system to water the parts of a field missed by a circular irrigator. The patent’s claims used means-plus-function language—that is, language describing means or steps for performing a function without a recitation of the supporting structure. This language is construed to apply to a corresponding structure described in the patent specification. Reinke Manufacturing Company, Inc. (Reinke) (defendant) sold an irrigation system that performed the same function as Valmont’s patented system. Valmont brought an infringement action in federal district court. The court found infringement on the basis of an equivalency analysis. More specifically, the court held that an equivalency existed between the means of control employed by Valmont’s system—an electric signal that caused the steering motors to pivot—and the means of control found in Reinke’s product. However, unlike Valmont’s system, Reinke’s system received signals from a buried electromagnetic cable. Reinke appealed to the United States Court of Appeals for the Federal Circuit.

Rule of Law

Issue

Holding and Reasoning (Rader, J.)

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