Case: Patents/Summary Judgment (Fed. Cir.)

The Federal Circuit affirmed the decision of the District of Utah granting Powerteq LLC’s motion for summary judgment of invalidity under the pre-America Invents Act version of 35 U.S.C. §102(b), in Infinitive Holdings LLC’s action for infringement of patent claims relating to reprogramming engine controllers. According to the appeals court, the district court didn’t erroneously rely on inadmissible hearsay, and Section 102(b)'s on-sale bar isn’t limited to sales expressly disclosing the prior art device’s functionality.