Helene Curtis Industries, Inc. v. Sales Affiliates, Inc.

161 F. Supp. 345, 117 U.S.P.Q. (BNA) 136, 1958 U.S. Dist. LEXIS 2374
District Court, S.D. New York·Decided March 27, 1958·Published·Cited by 3 cases

Opinion

IRVING R. KAUFMAN, District Judge.

On April 30, 1954, this Court held, in a declaratory action between the parties to the instant proceeding, that defendant’s U. S. Patent No. 2,577,-710 (hereinafter called “710”) was invalid.1 At that time, the defendant had a continuation-in-part application pending before the Patent Office. In January 1955, the defendant assigned that application to a Virginia Corporation, Tidewater Patent Development Company (hereinafter called “Tidewater”). On February 28, 1956, the application ripened into a granted patent, U. S. Patent No. 2,736,323 (hereinafter called “323”), and actions against plaintiffs’ customers in Virginia were instituted by Tidewater charging infringement of the 323 patent by the sale of plaintiffs’ products. Plaintiffs thereupon applied to this Court for an order holding defendant in contempt of the injunctive provisions of the 710 decree 2 and for an order expanding the scope of that decree to enjoin defendant from prosecuting the Virginia actions. They based their request for relief upon the contentions that the findings of fact and conclusions of law embodied in the 710 judgment necessarily render the 323 patent invalid as against the plaintiffs; and that Tidewater is controlled by the defendant so that Tidewater’s actions are, in effect, those of the defendant.

On consent of the parties, the matter was referred to the Special Master who had heard the testimony and reported in the original action, Honorable Simon H. Rifkind, for findings on the issues of law and fact raised by the application. After lengthy hearings and thorough consideration, the Master reported that plaintiffs’ allegations were correct. He nevertheless recommended that the relief sought be denied. On motion to confirm the Master's Report, I agreed that the facts did not warrant holding the defendant in contempt of the 710 decree and concurred in the Master’s doubts regarding the power and propriety of this Court’s enjoining the defendant from prosecuting the Virginia actions.3 The Court of Appeals, while affirming the denial of the motion for contempt, held, by a divided court, that if the Master’s findings with regard to plaintiffs’ allegations are found correct, this Court would have power to grant a supplemental injunction.4 It thereupon gave the following direction:

“ * * * the case is remanded to the District Court to pass upon the findings of the Special Master. If the District Court should confirm the findings that 323 is invalid for substantially the same reasons that 710 was invalidated, and that Tidewater was a mere alter ago of Sales Affiliates, then the District Court should issue an appropriate supplemental injunction.” (Italics added) 5

[347]*347I. Validity Of The 323 Patent

The validity of 323 is not to be determined as though this were a plenary proceeding. The plaintiffs are limited to showing that 323 is invalid for “substantially the same reasons” that 710 was invalidated, based upon the conclusions of law and findings of fact in the 710 litigation. The Master specifically limited himself to a determination of invalidity on this basis.6 He therefore excluded the issue of fraud in the procurement of the patent as extraneous to the issues adjudicated by the 710 judgment.7

The 710 patent was a sub-generic patent laying claim to a vast class of mercaptan compositions used for the permanent waving of human hair. Although the inventor McDonough apparently originally viewed the 710 patent as one for a new composition of matter, i. e. mercaptans,8 in view of the fact that a prior patent had specifically disclosed and claimed a species of mercaptan,9 the defendant relied primarily upon the assertion that 710’s validity rested upon the discovery that special laws and criteria govern mercaptans in hair waving.10 The 710 patent was found invalid for, inter alia, non-criticality in fact, lack of invention over prior art, and indefiniteness in the statement of the claims.

Prior to the issuance of the 710 patent, but more than eight years after its filing date, the inventor filed a divisional application with the Patent Office which eventually issued as the 323 patent. The application claimed a small group of mercaptan compositions which had been disclosed in the specifications of the earlier 710 application. Among the mer-captans included within this smaller class is thioglycolic acid, which is the principal mercaptan used in commercial permanent waving compositions today.

In the Patent Office, the inventor of 323 was required to change the designation of his application from “divisional” to “continuation-in-part” owing to the examiner’s contention that new matter had been inserted in the application. At the time, defendant’s counsel vigorously disputed the contention that there was any new matter in the 323 application.11 They now assert, however, that 323 does contain independent invention: the disclosure of “different criterion in the appreciation and selection of particular mercaptans for waving effectiveness.” 12 The Master found, however, that “[Cjomparison of the 323 patent with its parent, 710, reveals that the specifications of each are, save for minor additions and deletions, identical.” 13

Comparison of the specifications indicates that both contain the same general statement of the invention applied for, and the same teachings with respect to the pH of the mercaptan solutions, concentration, preferred bases and adjustment clause. While 710 referred to a broad class of mercaptans which included some 268 different mercaptans, 323’s specifications are limited to a group containing some 46 mercaptans. The principal subject matter of 323, thiogly-[348]*348colic acid, was referred to in 710 under the name of mercapto-acetic acid. There are three examples of the use of thio-glycolie acid in the 710 patent, all of which are repeated in 323. The deletions from 710 relate to statements that polar acidic mercaptans — i. e., thioglycolic acid and its homologues, are less effective than other mercaptans.

The principal difference in the specifications relates to the language of the molecular weight instructions.14 Defendant contends that the new language teaches for the first time that the structural formula of the mercaptan molecule, as well as its molecular weight, has an important bearing upon waving effectiveness. The defendant, however, urged in the 710 proceedings that 710 also taught the importance of structural formula, as well as molecular weight. I concur in the Master’s analysis that:

“In 323 the inventor simply notes, as he did in 710, that waving effectiveness is related to molecular weight especially where the increase in weight results from the addition of a polar group. The only difference between the two specifications is the inclusion of the polar alkaline group as inducing this phenomenon in addition to the polar acidic group originally disclosed.” 15

The claims of 323, although limited to a smaller class of mercaptans, are virtually identical to the claims of 710. The Master’s findings on this point are unassailable.

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Helene Curtis Industries, Inc. v. Sales Affiliates, Inc., 161 F. Supp. 345, 117 U.S.P.Q. (BNA) 136, 1958 U.S. Dist. LEXIS 2374 (S.D.N.Y. 1958).

161 F. Supp. 345 (Helene Curtis Industries, Inc. v. Sales Affiliates, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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