Short Summary: Design patent claims found invalid for obviousness.

Case: MRC Innovations, Inc. v. Hunter Mfg., LLP, No. 2013-1433 (Fed. Cir. Apr. 2, 2014) (precedential). On appeal from N.D. Ohio. Before Rader, Prost, and Chen.

Procedural Posture: Plaintiff patentee appealed grant of summary judgment finding patent invalidity. CAFC affirmed.

Design Patent: A court need not translate the claimed design into a “verbal description” as required under the Federal Circuit’s prior ruling in High Point Design LLC v. Buyers Direct, Inc., 730 F.3d 1301 (Fed. Cir. 2013), if the district court’s understanding of the patent claims is apparent from its opinion. Similarly, the specific motivations to combine features of a secondary reference need not be explicitly stated when “the mere similarity in appearance [ ] itself provides the suggestion that one should apply certain features to another design.”