Teleflex vs. KSR International Company 119 Fed.Appx. 282,2005 WL 23377 (C.A.Fed. (Mich.))  

(Federal Circuit Decision - Case pending before US Supreme Court)

Case Facts

Teleflex is the holder of a patent, relating to an adjustable pedal assembly for use with automobiles having engines that are controlled electronically with a device known as an electronic throttle control. Teleflex filed a patent suit against KSR, in the District Court, for the Eastern District of Michigan, alleging infringement of its patent. The District Court held Teleflex's patent to be invalid as it is obvious in the light of combination of prior art. Teleflex appealed to the Federal Circuit.

Issues

Is Teleflex's patent obvious in the light of teaching, suggestion and motivation to combine prior art references.

Holding 

No, the patent is not obvious in the light of combination of prior art references as there is no teaching, suggestion or motivation to combine the prior art.

Analysis

For an invention to be obvious in the light of multiple prior art references, there should be some teaching, suggestion or motivation for a person of ordinary skill in the art, to combine the relevant prior art teachings in the manner claimed in the patent. The teaching, suggestion or motivation to combine prior art references may be found explicitly or implicitly in the references themselves or knowledge of a skilled person in the art or in the nature of the problem to be solved.

The first prior art reference does not address the same problem addressed by the invention. While the objective of the patent was to design a smaller, less complex, and less expensive electronic pedal assembly, the prior art reference on the other hand, was directed at solving the 'constant ratio problem.' The second prior art reference fails to provide a sufficient motivation to combine because the prior art reference suffers from the problem, but does not address the problem solved by the patent in question. The third prior art reference, which states that the 'pedal assemblies must not precipitate any motion in the connecting wires', does not touch upon the issue of motivation to attach the electronic control on the support bracket of the pedal assembly.

Conclusion   

As none of the prior art references provide the teaching, suggestion or motivation to combine prior art in a manner claimed by the patent in question, the invention cannot be said to be obvious.