B/E Aerospace, Inc. v. C&D Zodiac, Inc, No. 19-1935 (Fed. Cir. 2020)Annotate this Case
On inter partes review (IPR) of B/E’s patents, the Patent Trial and Appeal Board found certain claims unpatentable as obvious. The patents relate to space-saving technologies for aircraft enclosures such as lavatory enclosures, closets, and galleys. The patents are directed to space-saving modifications to the walls of aircraft enclosures; they are not directed to the structures contained within those walls. The Federal Circuit affirmed, rejecting an argument that the Board incorporated a claim limitation that is not present in the prior art. The challenged claims would have been obvious because modifying a combination of prior art to include a second recess was nothing more than the predictable application of known technology. The Board fully articulated its conclusion of obviousness, and substantial evidence supports the Board’s determination of obviousness independent of whether it erred in considering design drawings.