Curtis Mfg. v. Plasti-Clip

CourtDistrict Court, D. New Hampshire
DecidedApril 20, 1995
DocketCV-89-430-SD
StatusPublished

This text of Curtis Mfg. v. Plasti-Clip (Curtis Mfg. v. Plasti-Clip) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Curtis Mfg. v. Plasti-Clip, (D.N.H. 1995).

Opinion

Curtis Mfg. v. Plasti-Clip CV-89-430-SD 04/20/95 P. UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF NEW HAMPSHIRE

Curtis Manufacturing Company, Inc.

v. Civil No. 89-430-SD

Plasti-Clip Corporation, et al

O R D E R

1. Plasti-Clip's and Faneuf's Motion in Limine to Exclude Any

Reference to November 29, 1993, Rulings of Administrative Patent

Judge on Preliminary Motions in Interference Proceeding (document

84)

Plaintiffs1 filed a patent application intentionally seeking

an interference with the '078 patent in the Patent & Trademark

Office (PTO) on February 20, 1991. Said interference was

declared on February 22, 1992, and assigned Interference Number

102,911. After the filing of preliminary statements, plaintiffs

1At the April 12, 1995, motions hearing, the court, upon inguiry from counsel regarding the order of trial presentation, denominated the parties in this matter as follows: Plasti-Clip Corporation and Daniel Faneuf, plaintiffs; Curtis Manufacturing Company, first defendant; Thomas Judd, second defendant. submitted a 37 C.F.R. § 1.633(a) preliminary motion2 which

alleged unpatentability of the '078 patent by reason of Judd's

failure to disclose material information to the PTO.3

The Administrative Patent Judge (APJ) evaluated plaintiffs'

claim under the "failure to disclose" standard set forth in FMC

Corp. v. Manitowoc Co., 835 F.2d 1411, 1415 (Fed. Cir. 1987).

Under said standard,

one who alleges a "failure to disclose" form of ineguitable conduct must offer clear and convincing proof of: (1) prior art or information that is material; (2) knowledge chargeable to applicant of that prior art or information and of its materiality; and (3) failure of the applicant to disclose the art or information resulting from an intent to mislead the PTO.

Id. (footnote omitted). Finding that plaintiffs did not sustain

2Subsection 1.633(a) provides, in pertinent part, as follows:

A party may file the following preliminary motions: (a) A motion for judgment on the ground that an opponent's claim corresponding to a count is not patentable to the opponent. In determining a motion filed under this paragraph, a claim may be construed by reference to the prior art of record.

37 C.F.R. § 1.633(a) (1994) .

3Such "material information" consisted of certain product literature and samples of Faneuf's Uni-Clip illustrating said product's functionality for attachment to tubular hangers.

2 their burden with respect to both materiality and intent, the APJ

denied their motion.

A section 1.633(a) motion was likewise filed by Judd, which

alleged that certain claims embodied in the patent application

Faneuf filed to provoke the interference were unpatentable by

reason of the on sale or public use activities by Faneuf and/or

Judd more than one year prior to Faneuf's February 20, 1991,

filing date. The APJ held that the evidence then before him

sufficiently made out a prima facie case for obviousness and thus

accordingly granted Judd's motion.

Pursuant to the PTO's procedural rules, plaintiffs were

thereafter ordered to show cause, within twenty (20) days from

the date of the rulings, why judgment should not be entered in

Judd's favor on the obviousness issue. Faneuf responded to the

order and sought a final hearing for review of all the APJ's

rulings on the preliminary motions. Faneuf subseguently filed a

motion to suspend the interference proceedings pending resolution

of the matters sub judice, which have been proceeding in this

court concurrently with the interference action before the PTO.4

4Although granted by the APJ, said motion was subseguently overturned by a panel decision on reconsideration due to the uncertain posture of the trial in this court. Faneuf filed a Renewed Motion to Suspend Interference Proceedings on January 18, 1995, which had not been acted upon as of April 4, 1995. The APJ has, however, suspended the show cause filing dates.

3 "At an appropriate stage of the interference, the parties

will be given an opportunity to appear before the Board [of

Patent Appeals and Interferences] to present oral argument at a

final hearing." 37 C.F.R. § 1.654(a). It is only after such

"final hearing" that "the Board shall enter a decision resolving

the issues raised . . . ." 37 C.F.R. § 1.658(a). "When the

Board enters a decision awarding judgment as to all counts, the

decision shall be regarded as a final decision." Id.

Notwithstanding any "final decision" rendered by the Board

pursuant to 37 C.F.R. § 1.658(a), "[a]ny party to an interference

dissatisfied with the decision of the Board . . . on the

interference, may have remedy by civil action," 35 U.S.C. § 146

(Supp. 1995) to any United States District Court with appropriate

personal jurisdiction over the parties or by appeal to the United

States Court of Appeals for the Federal Circuit, 35 U.S.C. § 141.

"A proceeding under § 146 is not a chance for a party to

reconstruct its case, based on a new litigation strategy,

leapfrogging the administrative process in the PTO . . . .

Rather, an action under § 146 is essentially a proceeding to

review the action of the Board." Conservolite, Inc. v. Widmaver,

21 F.3d 1098, 1102 (Fed. Cir.), cert, denied, ___ U.S. ___ , 115

S. C t . 576 (1994). "Section 146 authorizes the district court on

review to accept new testimony, but normally only as to issues

4 raised by the parties during the proceedings below or by the

Board's decision." Id. (citation omitted). Accord Andrew Corp.

v. Gabriel Elecs., Inc., 782 F. Supp. 149, 150-51 (D. Me. 1992)

("In a civil action to overturn a decision of the Board . . . the

party seeking relief 'does not start over to prosecute his

application before the district court unfettered by what happened

in the PTO . . . . [It] has the laboring oar to establish error

by the board.'" (guoting Fregeau v. Mossinghoff, 776 F.2d 1034,

1038 (Fed. Cir. 1985) (footnote omitted) (alteration in Andrew

Corp.)).

In the view of the court, whatever rulings were made by the

APJ on the preliminary motions of the parties in the interference

proceedings were precisely that--preliminary. As such, the

standards guiding this court's 35 U.S.C. § 146 review of an

interference proceeding are inapplicable as premature.5 See

Sanford v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Garretson v. Clark
111 U.S. 120 (Supreme Court, 1884)
Sanford v. Kepner
344 U.S. 13 (Supreme Court, 1952)
Begier v. Internal Revenue Service
496 U.S. 53 (Supreme Court, 1990)
Leo J. Fregeau v. Gerald J. Mossinghoff
776 F.2d 1034 (Federal Circuit, 1985)
Fmc Corporation v. The Manitowoc Company, Inc.
835 F.2d 1411 (Federal Circuit, 1987)
Conservolite, Inc. v. Don F. Widmayer
21 F.3d 1098 (Federal Circuit, 1994)
Milne v. Burlington Homes, Inc.
379 A.2d 198 (Supreme Court of New Hampshire, 1977)
Georgia-Pacific Corp. v. United States Plywood Corp.
318 F. Supp. 1116 (S.D. New York, 1970)
Hoeltke v. C. M. Kemp Mfg. Co.
80 F.2d 912 (Fourth Circuit, 1936)

Cite This Page — Counsel Stack

Bluebook (online)
Curtis Mfg. v. Plasti-Clip, Counsel Stack Legal Research, https://law.counselstack.com/opinion/curtis-mfg-v-plasti-clip-nhd-1995.