## Facts

- Allen Archery, Inc. owned U.S. Patent No. 3,486,495 directed to a “compound bow” using off-center mounted eccentric pulley members and a three-line laced bowstring with a central stretch and nocking point.
- Allen accused Browning Manufacturing Co., Browning & Bingham Projects, Inc., and related individuals of infringing claims 7, 8, 10, and 14 by making and selling compound bows embodying the claimed configuration.
- The parties’ dispute also involved a patent license agreement; Allen alleged Browning breached the agreement.
- Browning defended and counterclaimed, asserting invalidity (anticipation and obviousness), unenforceability for inequitable conduct based on nondisclosure to the USPTO, patent misuse, and antitrust violations.
- The district court (D. Utah) entered judgments rejecting inequitable conduct, finding the asserted claims valid and infringed, rejecting misuse and antitrust theories, finding a valid license and breach by Browning, and declining enhanced damages and attorney’s fees.

## Issues

1. Whether the patent was unenforceable for inequitable conduct based on alleged nondisclosure of prior art or information to the USPTO.
2. Whether the asserted patent claims were invalid for anticipation or obviousness.
3. Whether Browning’s accused compound bows infringed claims 7, 8, 10, and 14.
4. Whether Allen’s licensing or enforcement conduct constituted patent misuse or violated federal antitrust laws.
5. Whether the patent license agreement was valid and, if so, whether Browning breached it.
6. Whether the court should have awarded enhanced damages or attorney’s fees to Allen.

## Decision

- The Federal Circuit affirmed the district court’s judgments in all respects.
- The court held the record did not prove inequitable conduct; the patent remained enforceable.
- The court held Browning failed to prove invalidity by clear and convincing evidence; the asserted claims were valid.
- The court affirmed the finding that Browning’s products infringed claims 7, 8, 10, and 14.
- The court affirmed rejection of patent misuse and antitrust counterclaims.
- The court affirmed that the license agreement was valid and that Browning breached it.
- The court affirmed denial of enhanced damages and attorney’s fees.

## Legal Principles

- Inequitable conduct requires clear and convincing proof of materiality and intent to mislead or deceive the USPTO; nondisclosure alone, without intent, is insufficient.
- Patent invalidity must be proven by clear and convincing evidence; appellate review defers to supported district court factual findings underlying anticipation and obviousness determinations.
- Infringement findings may be affirmed where the accused device contains the claim elements and the district court’s claim application and factual determinations are not clearly erroneous.
- Patent misuse and antitrust liability require proof that the patentee impermissibly extended patent scope or engaged in conduct violating competition laws; unsupported allegations do not render a patent unenforceable or establish antitrust liability.
- Enhanced damages and attorney’s fees are discretionary and generally require willful infringement or an “exceptional case” showing; their denial will be upheld absent an abuse of discretion.

## Conclusion

The Federal Circuit upheld the enforceability and validity of the compound-bow patent, affirmed infringement and a license breach by Browning, rejected misuse and antitrust defenses, and sustained the trial court’s refusal to award enhanced damages or attorney’s fees.


Allen Archery, Inc. v. Browning Mfg. Co., 819 F.2d 1087 (Fed. Cir. 1987)