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Pfaff v. Wells Electronics, Inc. | 525 U.S. 55 (1998)

Under United States patent law, an inventor can’t obtain a patent on an invention that’s been on sale for more than a year before a patent application is filed. This straightforward-sounding rule often causes significant disagreement among the parties to a patent dispute. In Pfaff versus Wells Electronics, the United States Supreme Court tried to help out.

In November of 1980, Texas Instruments asked Wayne Pfaff to develop a new computer chip socket. Pfaff prepared detailed engineering drawings describing the design for the socket’s manufacture. In February or March of 1981, Pfaff sent the drawings to a manufacturer. As was usual for him, Pfaff didn’t make a prototype.

On April 8th, 1981, Texas Instruments sent Pfaff a purchase order for several thousand sockets. Because the manufacturer needed to retool its machinery to make the socket, the completed sockets weren’t delivered to Texas Instruments until July of 1981. On April 19th, 1982, Pfaff applied for a patent for the socket, which was granted in 1985.

Wells Electronics manufactured a competing socket. Pfaff sued Wells for patent infringement, and the district court agreed. Wells argued that Pfaff hadn’t filed his patent application until more than a year after he first offered the socket for sale to Texas Instruments. But the district court concluded that, because the socket hadn’t been reduced to practice, meaning turned into a physical object, until July of 1981, Pfaff’s patent application was timely and valid.

The Federal Circuit reversed, holding that, as long as Pfaff’s invention had been substantially complete at the time of the sale, the one-year period for filing an application had begun to run. Because the sale occurred on April 8th, 1981, Pfaff filed his patent application too late. The United States Supreme Court granted cert.

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