Odetics, Inc. v. Storage Technology Corp.

Odetics (plaintiff) held a patent on a robotic tape storage system with a "rotary means" comprising bins, a rod, and a gear that rotated the bin assembly when force was applied; Storage Technology Corporation and others (defendants) built a competing Library Storage Module using "bin arrays" rotated instead by cam followers pressed against cams. Odetics's robotics expert testified the cam-follower mechanism performed the identical rotary function in a way substantially equivalent to the patented gear mechanism, and the jury found literal infringement of the means-plus-function claim; the district court initially denied STK's motion for judgment as a matter of law but later reversed itself sua sponte and granted STK judgment as a matter of law, prompting Odetics's appeal.