Narrative Opinion Summary
The case involves a patent infringement dispute between Norian Corporation and Stryker Corporation, concerning U.S. Patent Nos. 5,336,264 and 6,002,065. Norian alleged that Stryker's BoneSource products infringed these patents, which pertain to calcium-phosphate compositions for medical applications. The court, after extensive proceedings, found Stryker infringed certain claims of the '264 patent, but the jury later invalidated these claims based on prior art, including the 1991 IADR Extended Abstract. The court examined issues such as whether the abstract qualified as a printed publication and the necessity of corroboration in patent invalidity cases. Despite Norian's claims, the jury found no willful infringement and ruled in favor of Stryker, citing obviousness and lack of a reasonable royalty rate, leading to a final judgment upholding the jury's findings of invalidity and rejecting Norian's post-trial motions.
Legal Issues Addressed
Corroboration Requirement in Patent Invaliditysubscribe to see similar legal issues
Application: The court discussed the necessity of corroboration for oral testimony in proving public accessibility of prior art.
Reasoning: The court concludes that additional corroboration is not needed for this issue, noting that corroboration is typically beneficial when documented evidence is expected.
Obviousness under 35 U.S.C. § 103subscribe to see similar legal issues
Application: The jury concluded that the claims of the '264 patent were obvious in view of the prior art references such as the '161 and '888 patents.
Reasoning: The order addresses the issue of obviousness, indicating that the jury could reasonably find the claims in question obvious based on two prior-art references: the '161 Brown and Chow patent and the '888 Iwamoto patent.
Patent Infringement under U.S. Patent Lawsubscribe to see similar legal issues
Application: The court ruled on the infringement of Claims 1, 7, and 8 of the '264 patent by Stryker's sale of its BoneSource products.
Reasoning: The court issued a ruling on February 13, 2002, confirming that Stryker's sale of its BoneSource products constituted infringement of Claims 1, 7, and 8 of the '264 patent.
Patent Validity and Prior Art under 35 U.S.C. § 102subscribe to see similar legal issues
Application: The jury found the invalidity of Claims 1, 7, and 8 of the '264 patent based on prior art, including the 1991 IADR Extended Abstract.
Reasoning: The jury dismissed the willful infringement claim and the laches defense, ultimately finding that Stryker demonstrated the invalidity of Claims 1, 7, and 8 based on prior art, specifically the 1991 IADR Extended Abstract.
Printed Publication Requirement under 35 U.S.C. § 102subscribe to see similar legal issues
Application: The court scrutinized whether the 1991 IADR Extended Abstract qualified as a printed publication, affecting the patent's anticipation claims.
Reasoning: The court found triable issues concerning whether certain references, including the 1991 and 1992 IADR Extended Abstracts, qualified as 'printed publications' under 35 U.S.C. § 102.