Judgment details from Color Kinetics & Super Vision case
The judge's ruling from the recent patent case, which ended in a clear victory for Color Kinetics, contains some instructive information.
LEDs Magazine has obtained a copy of the judge's ruling in the recent patent case between Color Kinetics and Super Vision, which resulted in several summary judgement rulings in favor of CK (see Color Kinetics wins summary judgment against Super Vision).
Despite the setback, SV remains confident that it will have more success in front of the U.S. Patent Appeals Court in Washington. Ultimately, SV is seeking to have the issues of validity, infringement and prior art tried before a jury.
Lack of evidence
The ruling from the U.S. District Court in Massachusetts makes interesting reading. The judge's conclusions were emphatically in favor of Color Kinetics, and stated that SV had failed to provide any evidence that supported its claims of inequitable conduct by CK, or that CK's patents should be ruled invalid.
Likewise, SV was unable to present evidence to disprove CK's assertions that various CK products infringed CK's patents. In considering infringement, the court ignored any allegations that the patents asserted were invalid, since this is irrelevant to the infringement situation.
On the question of patent validity, SV had a difficult task form the outset. In law, a U.S. patent is presumed valid, so that "one attacking the validity of a patent must present clear and convincing evidence establishing facts that lead to the legal conclusion of invalidity." The judge ruled that SV failed to do this.
Validity may be challenged on three grounds: firstly, where a prior art reference anticipates the claimed invention. This means that a single piece of prior art must be presented for each and every claim in the invention.
Secondly, invalidity can result if prior art renders the claimed invention obvious. Obviousness is difficult to prove and it is not sufficient to select elements from various prior art references and fit them to the claims in question.
Thirdly, a patent is invalid if the patent specification does not permit enablement of the claimed invention; in other words it must teach how to build the product described in the invention.
The judge concluded that "Super Vision's contentions [with respect to validity] fail to raise any factual triable issues regarding patent validity that can withstand summary judgment."