Del Mar Avionics, a California Corporation v. Quinton Instruments Company, a Washington Corporation

This case involves the applicability of the related doctrines of res judicata and collateral estoppel to a patent infringement suit brought against a manufacturer in the District Court for Seattle, based on a judgment of infringement against a distributor of the same product in the District Court for Los Angeles. Because defendant Quinton Instruments, Inc. (“Quinton”) was bound by the Los Angeles court’s determination that it controlled the Los Angeles litigation against its distributor Physio-Tronics, Inc. and was thus precluded from relitigating the Los Angeles court’s substantive findings on patent validity and infringement, summary judgment in favor of Del Mar Avionics, Inc. (“Del Mar”) in the instant action was proper. Furthermore, the trial judge did not abuse his discretion in denying Quinton’s requested injunction against enforcement of the Los Angeles injunction.

Del Mar brought an infringement action against Physio-Tronics, a California distributor for Quinton, in the United States District Court for the Southern District of California on October 21, 1974 (the “Los Angeles suit”). Although Quinton was not a named party in this action, it contracted to indemnify…