Automotive Technologies International Inc. v. BMW of North America, Inc.
United States Court of Appeals for the Federal Circuit
501 F.3d 1274 (Fed. Cir. 2007)
Automotive Technologies International, Inc. (ATI) (plaintiff) held a patent on side-impact crash sensors for airbags, describing a detailed, preferred mechanical sensor with five figures, but giving only a cursory description and a single conceptual figure for an alternative electronic sensor, in a field the patent itself described as new. Delphi (defendant) argued the patent was invalid because it did not enable a person of ordinary skill to make or use the electronic version without undue experimentation; the district court agreed and granted Delphi summary judgment despite ATI's expert testimony that existing electronic front-sensor technology could be adapted, and ATI appealed.
Whether, to fulfill the enablement requirement, a patent specification must provide reasonable detail sufficient for a person skilled in the art to make or use the full scope of the invention, rather than simply a starting point for further research.