Thursday, June 09, 2005

CAFC affirms obviousness in Princeton v. Beckman

In yet another case inconsistent with the brief of the 24 law professors, the CAFC affirmed an obviousness determination of a district court.

Writing in Princeton Biochemicals v. Beckman Coulter, Judge Rader (joined by Judge Schall and Gajarsa) affirmed a district court determination that a jury verdict finding of nonobviousness was not supported by substantial evidence. Thus, Princeton's US 5,045,172 remains invalid for obviousness.

The only issue in the case was "motivation to combine," exactly the issue attacked in the brief of the 24 law professors.

Judge Rader cited to Ruiz, 357 F3d 1270 (CAFC 2004) as well as to Rouffet, 149 F3d 1350. The CAFC credited testimony by a Dr. Jorgensen that motivation to combine was found in the knowledge of those skilled in the art, with a citation to Sibia, 225 F.3d at 1356. The CAFC also noted that the nature of the problem supplied motivation.


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