Circuit Check, Inc. v. QXQ Inc., No. 15-1155 (Fed. Cir. 2015)
Annotate this CaseManufacturers of circuit boards used in electronic devices, use circuit board testers before the boards are integrated into finished products. Many testers require an interface plate, which is a plastic grid with holes that permit connections between the tester and the circuit board. In order to align circuit boards during testing, it is advantageous to mark certain holes on the interface plate. Prior art methods of marking interface plates included placing Mylar masks on the surface of the interface plate, painting the surface of interface plates, and making shallow drill marks on interface plates. The Circuit Check patents claim systems and methods related to marking interface plates. Circuit Check sued QXQ alleging that QXQ’s interface plates infringed its patents. QXQ stipulated to infringement and the parties stipulated that three references describing interface plate marking techniques were prior art to the patents. The jury found the asserted claims not invalid for obviousness, found that the infringement was willful, and awarded damages. The court entered judgment as a matter of law that the asserted claims are invalid as obvious. The Federal Circuit reversed, finding the verdict that the disputed references were not analogous to be supported by substantial evidence.
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