The U.S. Court of Appeals for the Federal Circuit (CAFC) issued a significant ruling in Steuben Foods, Inc. v. Shibuya Hoppman Corp., reversing a district court's noninfringement decision on grounds that the reverse doctrine of equivalents (RDOE) had not been properly applied. The CAFC expressed that the lower court erred in granting judgment as a matter of law (JMOL) after a jury verdict and noted the compelling arguments raised by Steuben Foods regarding the application of RDOE, which the court affirmed is not subsumed by the 1952 Patent Act.
[T]he CAFC found no reason to affirm a noninfringement ruling under the reverse doctrine of equivalents (RDOE) for the first time ever, since it was improper for the district court to grant JMOL in this case.
The Federal Circuit reversed noninfringement findings made under the reverse doctrine of equivalents (RDOE), declining to declare the doctrine subsumed by the 1952 Patent Act, but finding that Steuben Foods raised 'compelling' arguments.
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