Armour and Company v. Swift & Company

466 F.2d 767
CourtCourt of Appeals for the Seventh Circuit
DecidedSeptember 18, 1972
Docket71-1197
StatusPublished
Cited by19 cases

This text of 466 F.2d 767 (Armour and Company v. Swift & Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Armour and Company v. Swift & Company, 466 F.2d 767 (7th Cir. 1972).

Opinion

STEVENS, Circuit Judge.

Hansen’s application for a patent on a process for assembling pieces of turkey meat into a boneless roast was originally *769 rejected as obvious in view of the prior work of Maas. 1 2Armour persuaded the Patent Examiner that Maas’ disclosure related to red meat which had not passed through rigor mortis, and that Hansen’s discovery that essentially the same process would work with post-rigor poultry meat was patentable. The primary issue here is whether the Examiner’s second or his first, appraisal of the invention was correct. 2

We think an artisan who was familiar with the Maas process, without really knowing why it worked, would nevertheless have tried to use it on poultry meat if he was seeking a comparable result; we also think it would have been obvious to an analyst who understood why the process worked that it would also be successful with poultry meat. The question is whether incorrect or misunderstood hypotheses in the art at the time of Hansen’s discovery made it nonobvious. We do not have the benefit of the Examiner’s judgment on this precise issue because Armour apparently persuaded him that an incorrect hypothesis was valid. The district court found that Armour then knew, or should have known, better. An understanding of how the issue arose requires a fairly complete statement of the facts.

I.

In May and June of 1964, Armour introduced a new boneless turkey roast into selected test markets. The product had a natural texture, did not lose its flavor or moisture during cooking, and could be sliced easily without crumbling or coming apart. It was a marked improvement over earlier attempts to combine chunks of meat with string or with adhesives such as gelatin or wheat gluten. It received prompt and widespread consumer acceptance.

Equally promptly it was copied by Swift. In August of 1964 a Swift research team thawed out an Armour roast, tore it apart, and identified the process by which it had been put together. The basic process can be simply described.

When chunks of meat are agitated in a salt solution a tacky exudate forms on the surface of the chunks; when they are pressed together and cooked, adjacent pieces are cemented to one another almost as though they originally comprised one large piece. Results are affected by the temperature during agitation, the extent of agitation, the amount of salt in the solution, and the character of the meat; however, the key to the process is the use of protein within the meat itself as the agent which cements the pieces together. Swift had not found this key until it analyzed Armour’s product in 1964.

Armour applied for the patent in suit 3 on March 16, 1964; the patent issued on November 15, 1966. This infringement action followed. After a long trial the district court, 320 F.Supp. 433, held the patent invalid; the court found that Hansen’s invention had been anticipated by the work of Maas at Oscar Mayer 4 ***, and by the work of Dr. Baker at Cornell University 5 , that the process would have been obvious to one of ordinary skill in the art at the time the alleged invention was made 6 , and *770 that Armour had breached its obligation of candor to the Patent Office. 7

Armour appeals, urging that the findings are clearly erroneous. It argues that Maas’ work on poultry to the extent that it preceded Hansen’s discovery had been either “concealed” or “abandoned” within the meaning of § 102(g) 8 , that Dr. Baker’s work related to an emulsion composed, in part, of ground poultry meat, unlike the chunks bound together by Maas and Hansen; that Swift’s failures demonstrated that Armour’s success was anything but obvious; and that its disclosures to the Patent Office were accurate if appraised in a correct temporal context and its nondisclosures were inadvertent and insignificant.

We agree with Armour that it is imperative that prior art, as well as Patent Office proceedings, be analyzed without reliance on after-acquired knowledge. As so analyzed, however, we are satisfied that the district court correctly concluded that this patent is invalid. The defects in Armour’s prosecution of the patent application overcome the normal presumption of validity. Moreover, Hansen’s probable knowledge • — which we treat as actual knowledge in view of every inventor’s presumed familiarity with the totality of relevant prior art 9 — of work which Maas had done at Oscar Mayer before Hansen left that company and joined Armour in 1962 and which was the subject of a patent application by Maas adequately explains the contrast between Armour’s success and Swift’s failure.

We first analyze the state of the prior art as of September 24, 1962, when Hansen’s conception was disclosed to Armour’s Patent Department. 10 We then *771 contrast Armour’s representations to the Patent Office on May 26, 1966, with what Armour actually knew, or as the district court found, should have known, on that date. It was Armour’s filing on that date which persuaded the Examiner to reverse his original rejection of the Hansen application as obvious in view of the work of Maas. 11

II.

Several hours after an animal dies, its muscles pass through rigor mortis. The proteins actin and myosin, which are normally separate in living and pre-rig- or tissue, combine to form actomyosin in post-rigor tissue. The binding agent in the tacky exudate which agitation brings to the surface of the meat chunks in the Hansen or Maas process is either myosin, actomyosin, a combination of both, or even possibly something else. Swift contends that it is actomyosin; Armour claims that it is myosin, or at least at the time of Hansen’s invention, the “art” taught that it was.

Under Armour’s theory of the case, successful binding was only possible if adequate amounts of myosin could be extracted by the agitation process. Under this theory, the fact that the amount of available myosin would decline drastically when meat passed through rigor mortis made it necessary to use pre-rigor meat in the Maas process. According to Armour, the teaching of Maas applied only to pre-rigor red meat. The Hansen discovery was that poultry — unlike red meat — could be successfully processed after rigor mortis had taken place because enough myosin survived rigor to achieve an adequate bind. Alternatively, the theory of the discovery was that perhaps, contrary to the teaching of the art, it was not myosin after all that effected the binding but something else. 12

*772

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466 F.2d 767, Counsel Stack Legal Research, https://law.counselstack.com/opinion/armour-and-company-v-swift-company-ca7-1972.