Rite-Hite Corporation v. Kelley Company, Inc.
United States Court of Appeals for the Federal Circuit
56 F.3d 1538 (1995)
Rite-Hite Corporation (plaintiff) held a patent (the '847 patent) on a vehicle-restraint device used at loading docks and sued competitor Kelley Company (defendant) for infringement; the district court found infringement and, at the damages phase, awarded Rite-Hite lost profits both for its patented restraint and for a second, non-patented restraint model (the ADL-100) that competed directly with Kelley's infringing product, plus lost profits on dock levelers sold alongside the restraints. Kelley appealed the damages awarded for the ADL-100 and the levelers.
Whether a patent holder may recover lost profits on sales of its own non-infringing product when those lost sales were caused by, and reasonably foreseeable from, the infringement of a different, patented product.