Question: Wayne Pfaff began development work on a new computer chip
Wayne Pfaff began development work on a new computer chip socket in November 1980. He prepared detailed engineering drawings that described the design and dimensions of the socket and the materials to be used in making it. Pfaff sent the drawings to a manufacturer in February or March 1981. Prior to March 17, 1981, he showed a sketch of his concept to representatives of Texas Instruments. On April 8, 1981, the Texas Instruments representatives provided Pfaff a written confirmation of a previously placed oral purchase order for 30,100 of the new sockets. The total purchase price was $91,155. In accordance with his usual business practice, Pfaff did not make and test a prototype of the socket before offering to sell it. The manufacturer to which Pfaff sent his drawings took a few months to develop the customized tooling necessary to produce the socket. The first actual sockets were not produced until the summer of 1981. Pfaff filled the Texas Instruments order in July 1981. Other orders followed, as the socket became a commercial success. On April 19, 1982, Pfaff applied for a patent on the socket. A patent was issued to him in January 1985. Pfaff later filed an infringement action against Wells Electronics, Inc., which produced a competing socket. Wells Electronics argued that Pfaff's patent was invalid under § 102(b) of the Patent Act of 1952, which stated that a patent cannot be obtained for an invention if it has been "on sale" for more than a year before the filing of the patent application. The federal district court rejected Wells Electronics' § 102(b) defense because Pfaff had filed the patent application less than a year after reducing the invention to practice (i.e., less than a year after the first actual sockets were produced and available for sale). The district court held Wells Electronics liable for infringement but the U.S. Court of Appeals for the Federal Circuit reversed. The Court of Appeals held that Pfaff's patent was invalid because the socket had been offered for sale on a commercial basis more than a year before the filing of the patent application. Was the Court of Appeals correct in invalidating the patent on that basis?
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