AUTOMOTIVE BODY PARTS ASSOCIATION v. FORD GLOBAL TECHNOLOGIES, LLC

AUTOMOTIVE BODY PARTS ASSOCIATION v. FORD GLOBAL TECHNOLOGIES, LLC, Appeal No. 2018-1613 (Fed. Cir. July 23, 2019).  Before Hughes, Schall and Stoll.  Appealed from E.D. Mich. (Judge Michelson). (Design Patent Subject Matter Eligibility)

Background:

Automotive Body Parts Association (ABPA), a trade association for auto parts distributors, brought suit challenging the validity of Ford’s design patents after Ford sent cease and desist letters to certain association members.  The patents cover designs for hoods and headlamps on the F-150 pickup truck.

At district court, ABPA argued Ford’s designs were primarily functional and thus not proper subject matter for design patents under 35 U.S.C. §171, which requires the designs to be ornamental.  Specifically, ABPA argued Ford’s hoods and headlamps provided a functional benefit because consumers seeking replacement parts would desire parts that were aesthetically compatible with their vehicles.  The district court found ABPA’s arguments without merit and entered judgment in favor of Ford sua sponte.  ABPA appealed.

Issue/Holding:

Did the district court err in granting summary judgment of validity?  (continue reading)

Summary by:  Graham Nelson

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