American Safety Flight Systems, Inc. v. The Garrett Corporation

Appellee (American) instituted suit under 28 U.S.C. § 1338 (a) and § 2201 against appellant (Garrett) for a declaratory judgment that Claims 1 and 2 of Garrett’s patents, Nos. 2,764,766 (Boyle-Taylor) and 2,804,633 (Taylor-Fraebel) were invalid and not infringed. Garrett counterclaimed, alleging infringement of both patents and praying that both be adjudged valid and infringed in their entirety. As an affirmative defense to American’s suit, Garrett alleged that American was barred by res judicata from contesting the validity of the Taylor-Fraebel patent in view of a prior decision by the Court of Claims upholding the validity of Claims 1-3 of the patent. Garrett Corporation v. United States, 422 F.2d 874 , 190 Ct.Cl. 858 , cert. denied, 400 U.S. 951 , 91 S.Ct. 242 , 27 L.Ed.2d 257 (1970).

The District Court held that American was not barred by res judicata and that Claims 1 and 2 of the Boyle-Taylor patent and Claims 1, 2 and 3 of the TaylorFraebel patent were invalid for obviousness under 35 U.S.C. § 103 . The District Court also held the patent claims invalid because ,of its finding that they combined individually old elements in an old life raft combination wherein no…