Tokai Corp. v. Easton Enterprises Inc.

Case Number: CLB0271

Date: 01.31.2011

Citation: 97 U.S.P.Q.2d 1673 (Fed. Cir. 2011)

Federal Circuit affirmed summary judgment of invalidity for obviousness finding that there was no material factual dispute regarding scope and content of prior art, differences between prior art and asserted claims, level of ordinary skill in the art and secondary considerations since components required to assemble claimed inventions are simple mechanical parts that are well known in the art, and need for safer utility lighters was recognized as of the priority date of the patents-in-suit, since parties agree that cigarette lighters and utility lighters are analogous arts, and person of ordinary skill would thus be directed to claimed safety utility lighters by combining available utility lighters with prior art automatic locking mechanisms on cigarette lighters, and since undisputed facts therefore compel conclusion of obviousness, which cannot be overcome by plaintiff’s far weaker showing of secondary considerations.

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