Vehicular Tech. Corp. v. Titan Wheel Int'l, Inc.
United States Court of Appeals for the Federal Circuit
141 F.3d 1084, 46 U.S.P.Q.2d 1257 (1998)
- Written by Sara Adams, JD
Facts
Vehicular Technologies Corporation (PowerTrax) (plaintiff) owned U.S. Patent No. 5,413,015 (the 015 patent). The 015 patent disclosed a locking differential that offered many improvements on prior differentials, including a newly formulated spring system made of a pin and two concentric springs. Two years prior to the issuance of the 015 patent, PowerTrax introduced the Lock-Rite, which implemented the new differential. The written description in the specification of the 015 patent repeatedly highlighted that a primary benefit of the concentric-spring system was that the inner spring could be used as a backup for the outer spring if the outer spring malfunctioned. A market competitor of PowerTrax, Titan Wheel International (Tractech), created the E-Z Locker by reverse engineering the Lock-Rite but implemented a spring system using a single spring and plug. Because the E-Z Locker only included a single spring, there was no backup in the event of a spring failure. PowerTrax sued Tractech for infringement of the 015 patent under the doctrine of equivalents and requested a preliminary injunction. The district court granted the preliminary injunction in favor of PowerTrax without considering the backup-spring function present in the Lock-Rite and absent in the E-Z Locker. Tractech appealed.
Rule of Law
Issue
Holding and Reasoning (Clevenger, J.)
Dissent (Newman, J.)
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