## Facts

- Wyers owned patents directed to barbell-shaped hitch pin locks used to secure a drawbar or tow ball mount to a vehicle’s hitch receiver.
- The asserted claims focused on incremental features, including (i) removable sleeves to adapt the lock’s diameter to different receiver sizes and (ii) seal/sleeve structures intended to protect components from weather.
- Master Lock sold competing hitch pin locks that Wyers alleged infringed.
- The prior art included multiple barbell-shaped hitch lock and lock-as-hitch-pin designs, including Wyers’s own earlier patent disclosing substantially similar barbell-shaped lock structure.
- At trial, a jury found Master Lock did not prove obviousness by clear and convincing evidence; the district court denied Master Lock’s renewed motion for judgment as a matter of law (JMOL) on obviousness.
- Master Lock appealed, challenging validity under 35 U.S.C. § 103.

## Issues

1. Whether the asserted claims would have been obvious under 35 U.S.C. § 103 in view of prior art showing similar hitch pin locks and known mechanical features.
2. Whether, under KSR’s flexible approach, “common sense,” design incentives, and predictable results supplied a sufficient reason to combine known elements to reach the claimed removable-sleeve and sealing features.
3. Whether the evidence, viewed under the JMOL standard, permitted a reasonable jury to find the asserted claims nonobvious despite the prior art and asserted secondary considerations.

## Decision

- The Federal Circuit reversed the judgment and held the asserted claims invalid for obviousness as a matter of law.
- The court concluded that adapting known hitch pin lock structures with removable sleeves to fit different receiver sizes was a predictable use of known mechanical techniques to solve a known sizing problem.
- The court concluded that the asserted seal and weather-protection features were also obvious because weather seals and protective sleeves were known components, and the claimed arrangements reflected predictable design choices.
- The court held that the evidence did not show teaching away, unexpected results, or other facts sufficient to avoid obviousness under KSR.
- The court found that the secondary-consideration evidence (such as commercial success and copying) did not outweigh the strong showing of obviousness and was not tightly linked to the claimed features.
- The court ruled that JMOL should have been granted notwithstanding the jury’s verdict because obviousness is a legal question and no reasonable jury could find nonobviousness on the record.

## Legal Principles

- Obviousness under § 103 is a question of law based on underlying factual findings; appellate courts may reverse a verdict where the legal conclusion of obviousness is compelled.
- Under KSR, a combination of familiar elements according to known methods is likely obvious when it yields predictable results; a rigid teaching-suggestion-motivation requirement is improper.
- Reasons to combine may arise from design incentives, market forces, and common sense when addressing known problems with known solutions in the relevant field.
- In predictable mechanical arts, using established components (e.g., sleeves to adjust fit; seals to resist weather) for their known functions often supports a strong prima facie case of obviousness.
- Secondary considerations must be supported by a nexus to the claimed invention and cannot overcome a strong prima facie case absent persuasive linkage and weight.

## Conclusion

The Federal Circuit applied KSR’s flexible obviousness framework to hold that Wyers’s hitch pin lock claims were invalid because the removable-sleeve and sealing features amounted to predictable combinations and adaptations of known mechanical elements, and the secondary evidence did not change the legal result; the denial of JMOL was therefore reversed.


Wyers v. Master Lock Co., 616 F.3d 1231 (Fed. Cir. 2010)