Clare v. Chrysler Grp., LLC, No. 15-1199 (Fed. Cir. 2016)
Annotate this CaseClare sued Chrysler for infringement, based on Chrysler’s RamBox pickup truck storage system. RamBox is plainly visible and is stamped ‘RAMBOX’ in large lettering. Clare’s patents purport to add storage “without altering the external appearance of the bed and without significant reduction in the carrying capacity.” Storage area is in the side of the bed “adjacent [to] the wheel well area, and along the length of the bed.” The external side panel is used to access the storage. The only visible modifications to the external side panel are two vertical lines where the side panel is cut. The hinge is out-of-sight on the inside of the side panel; the latch and lock are out-of-sight on the interior side of the bed, so that “one would not readily recognize the modification to the bed ... those with intent to steal tools, etc. would not recognize the hidden storage.” The Federal Circuit affirmed construction of the “external appearance limitations,” agreeing that no reasonable juror could find that RamBox, with its numerous and obvious visible distinctions, is not obvious from the outward appearance of the truck, and summary judgment of invalidity on the remaining claims, for failure under the written description requirement of 35 U.S.C. 112.
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