Motionless Keyboard Co. v. Microsoft Corp.

Inventor Thomas Gambaro developed a keyboard prototype called the Cherry Model 5 and, before securing patents, showed visual presentations (without demonstrating actual operation) to investors under nondisclosure agreements that mostly expired in 1989; in June 1990, he disclosed the device to Sheila Lanier for a one-time typing test that required connecting it to a computer, and Lanier signed her own NDA that same day, with no evidence she used the device again afterward. Gambaro applied for patents in June 1991 and January 1993, assigned them to Motionless Keyboard Co. (MKC) (plaintiff), and when MKC sued Microsoft, Nokia, and Saitek (defendants) for infringement, the defendants argued the patents were invalidated by the public-use bar under 35 U.S.C. section 102(b), which the district court agreed with in granting summary judgment.