Malico Inc. v. Cooler Master USA Inc.
Addressing the need for factual findings to support a finding of
obviousness, the U.S. Court of Appeals for the Federal Circuit
vacated the lower court's decision invalidating a patent,
determining that the requisite findings to support an invalidity
determination of obviousness were not made. Malico Inc.
v. Cooler Master USA Inc., Case No. 13-1680 (Fed. Cir., Nov.
17, 2014) (Chen, J.) (non-precedential).
Malico sued Cooler Master and LSI Logic for infringement of its
patented heat sink technology for cooling electronic
components. Cooler Master and LSI introduced prior art and
expert testimony that Malico's patent was obvious in view of
pre-existing heat sink technology and moved for summary judgment on
invalidity. In opposing defendants' motion, Malico
offered no rebuttal expert testimony and failed to present
admissible evidence of secondary conditions. The district
court granted defendants' motion for summary judgment
