Wright Co. v. Paulhan
United States District Court for the Southern District of New York
177 F. 261 (1910)
- Written by Eric Miller, JD
Facts
The Wright brothers discovered that keeping their flying machine stable required warping—i.e., bending—of the wings, which were controlled by ropes. Wing-warping, in turn, required movement of the machine’s tail rudder, which was controlled by tiller ropes, to perform the necessary correction. The Wrights used a set of pulleys to connect the warping ropes to the tiller ropes. The Wrights secured a patent on the invention in the name of the Wright Company (plaintiff). The patent specification used means-plus-function language to describe the means by which the tail rudder was caused to make the correction. However, later pilots discovered that no connection between the warping ropes and tiller ropes was necessary if the pilot had manual control over both. The Wrights brought several infringement actions against other aviators, including Louis Paulhan (defendant), who made the rudder correction manually. The case came before Judge Learned Hand in the United States District Court for the Southern District of New York.
Rule of Law
Issue
Holding and Reasoning (Hand, J.)
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