Digest of Beriont v. GTE Laboratories, Inc., No. 2014-1424 (Fed. Cir. Feb. 4, 2105) (nonprecedential). On appeal from D. Mass. Before Lourie, O’Malley, and Reyna.

Procedural Posture: Inventor Walter J. Beriont appealed summary judgment that GTE Laboratories, Inc. et al. are joint owners of U.S. Patent No. 5,920,802. CAFC affirmed.

  • Inventorship: Beroint failed to prove his sole inventorship because the only evidence provided in this regard is his personal testimony that he disclosed the invention to the other inventor who then only constructed and tested the disclosed invention. However, Beriont’s own testimony is insufficient, as an inventor’s testimony regarding conception of invention must be corroborated.