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Linear Technology Corp. v. Micrel, Inc.

Judgment of invalidity due to on-sale bar reversed because, under new legal standard articulated in Group One, Ltd. v. Hallmark Cards, Inc. , evidence did not support a conclusion that an invalidating offer for sale occurred.

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Appealed from: United States District Court for the Northern District of California Chief Judge Marilyn Hall Patel

In this patent infringement case, Linear Technology Corporation (“LTC”) sued Micrel, Inc. (“Micrel”) for infringement of U.S. Patent No. 4,755,741 and Reexamination Certificate B1 4,755,741 (collectively, “the ’741 patent”), directed towards adaptive transistor drive circuitry. Following a bench trial limited solely to Micrel’s invalidity defense, the district court held the ’741 patent invalid due to the on-sale bar of 35 U.S.C. � 102(b). Linear Tech. Corp. v. Micrel, Inc., 63 F. Supp. 2d 1103, 1126-27 (N.D. Cal. 1999).

On appeal, LTC challenges the district court’s judgment of invalidity under section 102(b), and Micrel cross-appeals several of the district court’s evidentiary rulings excluding letters proffered by Micrel that purportedly support its argument that an invalidating offer for sale occurred.

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