Lisle Corp. v. A.J. Manufacturing Co.

Lisle Corporation (plaintiff) developed a tool for automotive steering-control repair and, before filing its patent application, delivered free prototypes to four repair shops without formal confidentiality agreements, though it regularly solicited testing feedback from the mechanics per company protocol. Co-inventor Daniel Williams testified the prototypes were distributed specifically to test how the tool fit different automobile models, that he modified the design based on mechanic feedback, that Lisle had prior working relationships with each mechanic despite no signed agreements, and that he believed the mechanics understood the prototypes were for testing purposes. When Lisle later sued A.J. Manufacturing (defendant) for infringement, A.J. argued the patent was invalid because the pre-application prototype distribution constituted public use more than a year before filing; a jury found the patent not invalid, the district court denied A.J.'s motion for judgment as a matter of law, and A.J. appealed.