The Gentry Gallery, Inc. v. The Berkline Corp.
United States Court of Appeals for the Federal Circuit
134 F.3d 1473 (1998)
Gentry Gallery (plaintiff) patented a sectional sofa design (the '244 patent) placing two same-facing reclining seats around a center console that specifically housed the recliners' controls, solving the common problem of L-shaped sectional recliners facing awkwardly different directions. Gentry sued The Berkline Corporation (defendant) for infringement over Berkline's similar sofa, which had two same-facing recliners separated by a center seat with a fold-down back usable as a tabletop, but placed the recliner controls somewhere other than that center console. The district court granted Berkline summary judgment of non-infringement but rejected its invalidity and unenforceability arguments, and Berkline appealed.
Whether a patent holder's infringement claims are limited to the specific invention, and its limitations, as described in the patent's written specification.