Garmin International, Inc. v. International Trade Commission
697 F. App'x 1007
| Fed. Cir. | 2017Background
- Navico filed a Section 337 petition alleging Garmin’s DownVü sonar imaging products infringed three Navico patents (the ’840, ’550, and ’499 patents); the ITC investigation followed and an ALJ held no violation but contingent infringement findings.
- The Commission reversed in part, finding Garmin’s products infringed claims of the ’840 and ’550 patents, and found some claims of the ’550 patent invalid; Garmin appealed to the Federal Circuit.
- The ’840 patent claims a sonar assembly with a single linear downscan transducer that produces fan-shaped beams (claim 1 representative). The ’550 patent (a continuation) claims an assembly of multiple linear transducer elements including a central downscan and lateral sidescans (claim 32 representative).
- The Commission relied on prior art Tucker (1960 echo-ranger article describing adjustable transducer, receiver, and printed recorder) and Betts (U.S. Patent disclosing linear sidescan and circular downscan elements and an electronic control head) in its validity analysis.
- The Federal Circuit reviewed the Commission’s factual findings for substantial evidence and legal questions de novo, and held that the Commission lacked substantial evidence to support its nonobviousness findings for many asserted claims.
Issues
| Issue | Plaintiff's Argument (Navico) | Defendant's Argument (Garmin) | Held |
|---|---|---|---|
| Whether Tucker (and Betts) disclose a "sonar signal processor" limitation and render claims obvious | Tucker lacks an express processor and thus does not disclose processing sonar returns into image data; claims not obvious | Tucker’s receiver and recorder disclose receiving transducer echoes and producing images; Betts discloses an electronic control head; combination renders claims obvious | Reversed Commission: Tucker + Betts disclose/teach the processor function and the claims are obvious over the combination (claims of the ’840 and claims 32,44 of the ’550) |
| Whether all claim elements (e.g., single linear downscan transducer) are present in prior art combination | The claimed single linear downscan element is not taught by Tucker/Betts | Garmin argued the references collectively disclose the single linear downscan element | Commission had found the single linear element present; Federal Circuit’s obviousness ruling rendered further construction on this infringement-related term unnecessary |
| Proper claim construction of "single linear downscan transducer element" (affecting infringement) | Navico urged a broader construction supporting infringement finding | Garmin urged narrower construction to avoid infringement | Court did not reach this claim-construction question because it found asserted claims invalid on obviousness grounds |
| Standard of review and sufficiency of evidence | N/A (procedural) | Commission’s factual findings must be supported by substantial evidence | Federal Circuit applied substantial-evidence review and reversed where record did not support Commission’s nonobviousness conclusion |
Key Cases Cited
- Spansion, Inc. v. Int’l Trade Comm’n, 629 F.3d 1331 (Fed. Cir. 2010) (substantial-evidence standard for review of ITC factual findings)
- Teva Pharm. USA, Inc. v. Sandoz, Inc., 574 U.S. 318 (2015) (claim construction may involve subsidiary factual findings)
- KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (2007) (obviousness and predictable use of prior-art elements)
- Graham v. John Deere Co. of Kansas City, 383 U.S. 1 (1966) (framework for obviousness analysis)
- Randall Mfg. v. Rea, 733 F.3d 1355 (Fed. Cir. 2013) (identifies Graham factors for obviousness analysis)