Astro Music, Inc., a California Corporation v. Richard Eastham and Betty Jean Eastham, D/B/A Veda Enterprises

Astro Music, Inc. appeals from the judgment of the district court that its patent on a guitar string-changing device was invalid and that defendants Richard and Betty Jean Eastham were not guilty of unfair competition. We affirm.

I. The Validity of the Patent

Astro Music’s patented device is a crank for tightening and loosening guitar strings which is also fitted with a slot for removing the pegs anchoring the strings to the bridge of the instrument. The slot also serves to accommodate larger tuning pegs in the tightening and loosening process. Neither the slotted peg-removing tool nor the crank were invented by Astro Music; its patent is based upon the combining of these two previously separate tools into one. The district court found that the patent was invalid because the device failed the test of nonobviousness of 35 U.S.C. § 103 . Although the ultimate question of patent validity is one of law, the § 103 requirement is heavily infused with factual determinations. Graham v. John Deere Co., 383 U.S. 1, 17 , 86 S.Ct. 684 , 15 L.Ed.2d 545 (1966). The district judge’s conclusion on this issue therefore must remain undisturbed unless he incorrectly understood or applied the § 103…