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Vehicular Tech. Corp. v. Titan Wheel Int'l, Inc.

141 F.3d 1084, 46 U.S.P.Q.2d 1257 (1998)

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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)

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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