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Leonard R. Kahn v. General Motors Corporation
Citations: 77 F.3d 457; 1996 WL 102036Docket: 95-1499
Court: Court of Appeals for the Federal Circuit; April 16, 1996; Federal Appellate Court
General Motors Corporation appeals a decision from the U.S. District Court for the Southern District of New York, which affirmed that Leonard R. Kahn holds title to patent 4,018,994 and has the right to sue for infringement. The court's ruling was based on the history of the patent’s ownership. Kahn initially assigned the patent application to Kahn Research Laboratories, Inc. (KRLI) in 1972, and later sold his controlling interest in KRLI to Electrospace Corporation, which was required to assign all patents back to Kahn. After KRLI's bankruptcy and dissolution in 1974, Kahn acquired KRLI's assets, including patent rights, through a public auction. The '994 patent was issued to Kahn in 1977 after he asserted that the application had not been assigned. General Motors contends that Kahn does not hold legal title to the patent, claiming that KRLI still retains ownership and that allowing Kahn to pursue the lawsuit creates a risk of double jeopardy. In contrast, Kahn argues he has reacquired all rights from KRLI and that the company has been defunct for over twenty years. General Motors was denied the opportunity to invoke the rights of a non-party, as neither party claimed such a party existed. The ownership of patent rights is a legal matter, subject to factual inquiries, with the court applying plenary review to legal issues and clear error review to disputed facts. The court did not need to determine whether KRLI's reassignment of the Grandparent Application retained any patent rights for future inventions. Any potential residual rights were resolved in 1974 when Mr. Kahn purchased all remaining assets from KRLI, thereby owning all present and future rights. The case cited by General Motors, Filmtec Corp. v. Allied-Signal Inc., is deemed irrelevant because Mr. Kahn had already recovered any residual rights by the time the '994 patent application was filed. The court found no cloud on Mr. Kahn's title to the '994 patent, confirming his sole ownership without any encumbrances from KRLI, which was dissolved over twenty years ago. While Mr. Kahn sought sanctions against General Motors for delay tactics since 1988, the request was not granted, although the resolution of the case was noted as overdue. The district court's decision was affirmed, and the case was remanded for further proceedings, with costs awarded to Mr. Kahn.