John Bean Technologies Corp. v. Morris & Associates, Inc.

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John Bean’s patent, directed to a chiller for cooling poultry carcasses, issued in 2002. Morris is the only other U.S. poultry chiller manufacturer. Weeks after the patent issued, Morris sent a letter stating that Bean had been contacting Morris’s customers and claiming that the equipment being sold by Morris infringed the patent. That Demand Letter notified Bean that Morris believed the patent to be invalid based on prior art and claimed unfair competition. Bean never responded. Morris continued to sell its chillers. In 2013, Bean requested ex parte reexamination. The Patent Office rejected both claims of the 622 patent as anticipated or obvious. Bean amended the two original claims and added six claims. The Patent Office issued a reexamination certificate under 35 U.S.C. 307 allowing the amended and newly added claims. Bean sued, alleging infringement from the date the reexamination certificate issued. In 2016, the district court granted Morris summary judgment, finding the infringement action barred by laches and equitable estoppel based on the 2002 Demand Letter. The Federal Circuit reversed, noting the Supreme Court holding in SCA Hygiene Products (2017), that laches cannot be asserted as a defense to infringement occurring within the six-year period before the filing of an infringement complaint as prescribed by 35 U.S.C. 286. Tthe allegedly infringing activity for which Bean sought damages started in 2014, and Bean filed its infringement complaint in 2014; SCA Hygiene bars Morris’s laches defense. View "John Bean Technologies Corp. v. Morris & Associates, Inc." on Justia Law