Redline Detection, LLC v. STAR Envirotech, Inc., No. 15-1047 (Fed. Cir. 2015)
Annotate this CaseSTAR owns a patent that describes methods for generating smoke that “enables the presence and location of leaks in a fluid system (e.g. the evaporative or brake system of a motor vehicle) to be accurately and visually detected depending upon rate of the air flow through the fluid system under test and whether smoke escapes from the system.” Redline sought inter partes review. The Patent Trial and Appeal Board denied Redline’s motion to submit supplemental information under 37 C.F.R. 42.123(a) and found Redline failed to show that claims of the patent would have been obvious. The Federal Circuit affirmed. The Board properly found that prior art, taken together, generate smoke via differing methods and thus, could not be combined to achieve the claimed invention recited in claims of STAR’s patent.
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