Douglas Dynamics, LLC v. Buyers Prods.Co., No. 11-1291 (Fed. Cir. 2013)
Annotate this CaseDouglas and Buyers manufacture snowplow assemblies for mounting on the front of a truck. Douglas commands about 60 percent of the market; Buyers entered the market in 2007, selling less expensive assemblies. By 2010, Buyers had a market share of about five percent. Douglas’s 700 patent claims a snowplow assembly that can be mounted on a vehicle and removed as a single unit. Patented features allow the user to remove heavy portions of the assembly from the vehicle when the plow is not in use, reducing stress on the vehicle’s suspension. The inventive mounting frame does not extend beyond the bumper upon removal of the snowplow assembly, reducing the likelihood the mounting frame will inadvertently cause damage. Douglas alleged infringement against Buyers. The district court granted summary judgment of non-infringement of the 700 patent. A jury found two other patents valid and infringed, but the court denied Douglas a permanent injunction and assigned an ongoing royalty. The Federal Circuit reversed with respect to the 700 patent, finding that the court applied an erroneous claim construction of “connected to”; remanded for entry of a permanent injunction with respect to another patent; and vacated the ongoing royalty rate.
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