## Facts

- W. H. Christie and Charles Seybold made competing claims to the same improvement in a bookbinder’s press, leading the Patent Office to declare an interference.
- The Patent Office awarded priority to Christie, issued him a patent, and rejected Seybold’s application.
- Seybold brought a civil action under Rev. Stat. § 4915 in federal court seeking a patent despite the adverse Patent Office decision; the trial court ruled for Seybold.
- Seybold claimed conception in October 1885 but did not build a working press until April 1889 and filed his application on June 6, 1889.
- Christie claimed conception in summer 1886, reduced the invention to practice in 1888, and filed on June 7, 1889 (one day after Seybold).
- Seybold attributed his delay to lack of tools and reluctance to complete the work in another person’s shop.

## Issues

1. In a contest between an earlier conceiver and an earlier reducer to practice, which party has priority when filing dates are nearly simultaneous?
2. Whether Seybold proved reasonable, continuous diligence from before Christie’s conception through Seybold’s reduction to practice or filing sufficient to preserve priority based on earlier conception.
3. What weight a court should give to the Patent Office’s interference decision in a Rev. Stat. § 4915 action, and what burden the challenger bears to overturn it.

## Decision

- The Sixth Circuit reversed the trial court and entered judgment for Christie.
- The court held that Seybold failed to prove the continuous diligence required to rely on his earlier conception date.
- The court treated the prior Patent Office interference determination in Christie’s favor as entitled to substantial weight and found Seybold’s evidence insufficient to displace it.
- Christie’s earlier reduction to practice, prompt filing, and the administrative award of priority supported Christie’s entitlement to the patent.

## Legal Principles

- As between competing inventors of the same invention, the first to reduce to practice generally prevails.
- An inventor who first conceives may nonetheless obtain priority over an earlier reducer to practice only by proving reasonable diligence in adapting and perfecting the invention from a time prior to the rival’s conception through the first conceiver’s reduction to practice or filing.
- In a Rev. Stat. § 4915 action challenging an adverse interference decision, the challenger bears a substantial burden to prove the Patent Office’s priority determination was erroneous; the administrative decision is not conclusive but is given significant weight.
- Explanations for delay that do not show sustained efforts toward completion are insufficient to establish the diligence required to carry an earlier conception date.

## Conclusion

The court reinstated Christie’s priority because Seybold’s earlier conception was defeated by Christie’s earlier reduction to practice and Seybold’s failure to prove continuous diligence, and because Seybold did not meet the evidentiary burden necessary to overturn the Patent Office’s interference award in Christie’s favor.


Christie v. Seybold, 55 F. 69 (6th Cir. 1893)