Bottom Line Management, Inc. v. Pan Man, Inc.
United States Court of Appeals for the Federal Circuit
228 F.3d 1352 (2000)
Bottom Line Management, Inc. (plaintiff) held a patent on nonstick cooking "platens" for two-sided burger cookers, made with studs welded to the back rather than bolts, giving a seamless surface for even Teflon coating; the patent itself allowed for removal and refurbishment. Pan Man, Inc. (defendant) refurbished used platens by re-coating them with Teflon and straightening or re-welding studs that customers had bent or broken removing them from the cookers. Bottom Line sued for patent infringement, arguing this refurbishment was impermissible reconstruction rather than allowed repair. The trial court granted Pan Man summary judgment, finding it was permissible repair, and Bottom Line appealed.
Whether only complete reconstruction of a patented product infringes the patent, such that mere repairs do not.