Crosley Radio Corporation v. Canadian General Electric Co. Ltd.

Crosley Radio Corporation v. Canadian General Electric Co. Ltd.

The recessed door with shelving, though useful and commercially successful, did not exhibit the requisite inventive ingenuity and was a natural, obvious development from existing cabinets and bulged doors; therefore it lacked patentable subject‑matter and the patent was invalid.

Citation
[1936] SCR 551
Parties
Appellant/plaintiff: Crosley Radio Corporation; Respondent/defendant: Canadian General Electric Co. Ltd.
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
17 June 1936
Procedural Posture
Patent Infringement / Patent Validity Appeal / Appeal to Supreme Court of Canada From the Exchequer Court of Canada (trial on Validity and Infringement)
Outcome
Appeal dismissed with costs
Legal Topics
Validity, Subject Matter, Inventive Step, Obviousness, Patent Reissue
Source Language
English
Intellectual Property Patent Law Validity Subject Matter Inventive Step Obviousness Patent Reissue

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Legal principles 3 Authorities cited 14 Party arguments 2
Sign in to unlock

Parties

Crosley Radio Corporation

Appellant/plaintiff

Canadian General Electric Co. Ltd.

Respondent/defendant

Procedural Posture

Patent Infringement / Patent Validity Appeal / Appeal to Supreme Court of Canada From the Exchequer Court of Canada (trial on Validity and Infringement)

Legal Issues

  1. 1 Whether the patented recessed refrigerator door with internal shelving involved patentable subject‑matter/invention
  2. 2 Whether the improvement was an obvious or mere workshop improvement not involving inventive ingenuity

Ratio Decidendi

The recessed door with shelving, though useful and commercially successful, did not exhibit the requisite inventive ingenuity and was a natural, obvious development from existing cabinets and bulged doors; therefore it lacked patentable subject‑matter and the patent was invalid.

Court Disposition

Appeal dismissed with costs

Orders

  • Appeal dismissed with costs