May 22, 2013
Federal Circuit Decisions for Week Ending May 17, 2013
Metso Minerals, Inc. v Powerscreen Int’l Dist., Ltd. 2011-1572, 2012-1168, -1169 (May 14, 2013) (non-precedential) (3-0) Patent No. 5,577,618
- A reference does not need to be fully functional to qualify as prior art; indeed, a prior art reference “need not work” and may even be “inoperative.”
- A district court’s error is harmless if the error could not have changed the result of the litigation.
Forrester Environmental Services, Inc. v. Wheelabrator Technologies, Inc. 2012-1686 (May 16, 2013) (precedential) (3-0) Patent Nos. 4,737,356, 5,430,233, and 5,245,114
- Patent law issues must be sufficiently substantial to create federal jurisdiction.
- Potential or hypothetical conflict between state and federal law regarding patent issues is not sufficient to confer federal jurisdiction.