KSR International Co. V. Teleflex Inc.

“Supreme Court broadened the standard for determining obviousness in patent cases”

Facts

Teleflex held a patent for an adjustable pedal system with an electronic throttle sensor. KSR developed a similar system and was sued for infringement. The district court ruled for KSR, finding the patent obvious. The Federal Circuit reversed, applying the 'teaching, suggestion, or motivation' (TSM) test strictly. The Supreme Court reviewed the standard for obviousness.

Issue / Question

What is the proper standard for determining obviousness under Section 103 of the Patent Act.

Findings / Reasoning

The Supreme Court rejected the rigid application of the TSM test. It held that courts should take a more flexible, common-sense approach to determine whether a patent combines prior art elements in a predictable way. Obviousness must consider the perspective of a person having ordinary skill in the art (PHOSITA).

Suggestions / Implications

Patent applicants must demonstrate clear innovation beyond combining existing ideas. This decision makes it harder to obtain patents for minor, predictable variations.

Judgment / Date

April 30, 2007 – Supreme Court unanimously reversed the Federal Circuit.