Honeywell International, Inc. v. Mexichem Amanco Holding S.A., No. 16-1996 (Fed. Cir. 2017)Annotate this Case
Honeywell’s 366 patent is directed to the use of 1,1,1,2-tetrafluoropropene, an unsaturated hydrofluorocarbon compound, and a polyalkylene glycol lubricant in heat transfer systems, such as air conditioning equipment. In merged inter partes examinations, an examiner rejected several claims under 35 U.S.C. 103. The Patent Trial and Appeal Board affirmed. The Federal Circuit vacated. The Board erred: by improperly relying on inherency to find obviousness and in its analysis of motivation to combine the references; in dismissing Honeywell’s evidence of unpredictability in the art when it stated that one of ordinary skill would no more have expected failure than success in combining the references; and in relying on a new grounds for rejection.