Maytag Co. v. Hurley MacHine Co.

Background

The disputes involve a Maytag Company patent for a washing machine issued July 12, 1932, which had thirty-nine claims: thirty-six for the machine itself and three for a method of washing (claims 1, 38, and 39). In 1935 Maytag won a district-court decree against the Brooklyn Edison Company on two machine claims and one method claim (38), but the Second Circuit later reversed those three claims. Maytag then formally disclaimed method claims 1 and 38, but did not disclaim claim 39. The present suits charge infringement of apparatus claims 23, 26, and 29, while claim 39 has not been sued upon in these cases.

Reasoning

The central question was whether Maytag’s failure to disclaim claim 39 made the whole patent void. The Court found that the company unreasonably delayed disclaiming claim 39 unless that claim was clearly different from the disclaimed method claims. Reading the claims in full, the Court concluded claims 38 and 39 describe the same washing method; their different wording did not change how the method works or its result. Because claim 39 was not disclaimed or used in suit, the Court held the patent void for that failure and therefore did not need to resolve a conflicting outcome from other courts about the apparatus claims.

Real world impact

The decision means Maytag cannot rely on the patent when a required overlapping method claim was not timely disclaimed. The Supreme Court affirmed two lower-court decrees and reversed one, changing which infringement rulings stand. Other companies and litigants must note that failing to disclaim overlapping claims can void a patent.