KSR International Co. v. Teleflex Inc.
Teleflex sued KSR International for infringing Teleflex's patent for an adjustable pedal assembly for engines controlled by an electronic throttle control (U.S. Patent No. 6,237,565 B1). Specifically, Teleflex complained that KSR International infringed claim 4 of the patent, which is a design of an assembly where the electronic control is mounted in the support bracket. KSR International argued that the claim was obvious and therefore invalid. A claim is obvious under 35 U.S.C. § 103(a) when the invention would be obvious to a person with ordinary skill in the art.
The district court granted KSR's motion for summary judgment, holding that the invention was obvious because every element of the invention existed in prior patents. On appeal, the United States Court of Appeals for the Federal Circuit reversed and remanded the case to district court. The court of appeals held that summary judgment was not appropriate because combining prior inventions is not obvious unless a person of ordinary skill would find it obvious to combine the inventions in that way.
Question Presented:
Whether the Federal Circuit has erred in holding that a claimed invention cannot be held "obvious," and thus unpatentable under 35 U.S.C. § 103(a), in the absence of some proven "'teaching, suggestion, or motivation' that would have led a person of ordinary skill in the art to combine the relevant prior art teachings in the manner claimed."
