No Public Use Bar To Patent Validity Where Product Demonstrations Were For Limited Number Of Persons To Obtain Feedback

摘要

In American Seating Co. v. USSC Group, Inc., 514 F.3d 1262 (Fed. Cir. 2008), American Seating, the owner of a patent for a wheelchair tie-down system for use in mass transit vehicles, sued USSC and others for, among other things, patent infringement. The trial court granted summary judgment on the issue of patent infringement, and a jury concluded that USSC had not shown that the tie-down system was in public use for one year before the patent application date, and awarded American Seating damages. On USSC's motion, the trial court reduced the damages award, and both parties appealed. The appellate court set out the law concerning patent invalidity due to the public use bar and its application to this case as follows.