District Court Cannot Rely Solely On PTO's Determinations To Find Patent Not Invalid

In Exmark Manufacturing Co. v. Briggs & Stratton Power Products Group, No. 2016-2197 (Fed. Cir. Jan. 12, 2018), the Federal Circuit vacated the district court's grant of summary judgment that Exmark's asserted patent was neither obvious nor anticipated.

Exmark sued Briggs, alleging infringement of Exmark's lawn mower patent. Briggs filed two reexaminations at the PTO and the PTO upheld the patent's validity. Exmark then filed a summary judgment motion in district court that the patent was not anticipated or obvious based on the PTO's decisions involving the same prior art. The district court granted Exmark's motion based solely on the outcome of these reexaminations. After trial, Briggs appealed this and other determinations.