1997),[1] was a case for the United States Court of Appeals for the Federal Circuit in which Lawrence B. Lockwood sued American Airlines, Inc for patent infringement for their reservation system, SABREvision.
In the summary judgment for that case, the court ruled that American Airlines, Inc's SABREvision system did not infringe on U.S. Patent Re.
Martens was one of the founding members of his firm and was later a mediator for the United States Court of Appeals for the Federal Circuit.
[13] Lockwood sued American claiming that their SABREvision reservation system infringed on the three patents he held, '115, '359, and '355.
[2] The district court ruled that SABREvision did not infringe this patent because it was not in violation of the following four parts of the asserted Claim 11: This patent is for "a system for automatically dispensing information, goods and services to a customer on a self-service basis including a central data processing center in which information on services offered by various institutions in a particular industry is stored".
This patent is for "An apparatus for composing individualized sales presentations created by various data sources from customer profiles managed by organizational hierarchy matrixes directed by multiple operating programs".
[4] The district court ruled that SABREvision did not infringe this patent because it did not "compose 'individualized sales presentations' or 'selectively combine' customer information to retrieve its photographs" as was asserted by Claim 1.
[1] The appellate court decides that, as American stated, despite the fact that certain implementation details of SABRE were "inner workings", the public knew and used these features, and so it constitutes prior art.
The district court ruled that not all of the third, fourth and fifth applications described the invention with accurate detail and therefore, patent '355 was not entitled to the earlier filing date.
Lockwood argued that the court only looked at the applications for the patents themselves, but failed to recognize that it was enough to show that he was "in possession" of the invention.
[1] The appellate court disagreed with Lockwood's argument and held that the conditions for being entitled to an earlier filing date can only be satisfied by what is described in the applications themselves, not to any ideas implied by them.
In addition, Lockwood argued that "customer" should be interpreted as "someone with whom you do business" (including travel agents who use SABREvision).
[1] American claimed that the patents expressly state that the point of the invention is to eliminate travel agents; therefore, the "customer" of both structures is different.
Lockwood disputed the district court's ruling that SABREvision's requirement of "manually selec[ting] and view[ing]" is not equivalent to "composing and displaying individualized sales presentations".