Patent Law Keyed to Adelman
KSR International Co. v. Teleflex, Inc.
Plaintiff held the exclusive license to the patent entitled "Adjustable Pedal Assembly with Electronic Throttle Control." One claim of the patent involved adding an electronic sensor to the pedal which then transmitted information to the computer controlling the engine's throttle. Defendant added an electronic sensor to its existing pedal design. Plaintiff sued Defendant for patent infringement. Defendant argued the claim by Plaintiff was invalid under 35 U.S.C. § 103 because the addition of the electronic sensor was obvious. The district court granted summary judgment to Defendant and Plaintiff appealed. The court of appeals applied the "teaching, suggestion, or motivation" [TMS] test and reversed. The Supreme Court granted the Defendant's writ of certiorari in order to address the obviousness analysis.
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