In re Icon Health & Fitness, Inc.
United States Court of Appeals for the Federal Circuit
496 F.3d 1374 (2007)
Icon Health & Fitness (plaintiff) sought a patent on a foldable treadmill using a gas spring to keep it stable when stored upright; the examiner rejected the claims as obvious over a Damark advertisement showing a folding treadmill (missing only the gas-spring feature) combined with the Teague patent, which showed a dual-action spring stabilizing a folding bed in both open and closed positions. Icon argued Teague, from a wholly different field, was not analogous art, but the Board found both patents shared the purpose of stabilizing a folding mechanism and affirmed the rejection.
Does prior art constitute analogous art in an obviousness inquiry if it is pertinent to the particular problem with which the inventor is involved, even if the art exists in a different field?