Separating Single Component into Two Components That Perform Same Function is “Generally Obvious”

The court granted plaintiffs' motion for summary judgment that defendant's conical crusher patent was invalid as obvious. "[T]he only question is whether separating the seal and piston into two unattached parts would have been obvious to a person having ordinary skill in the art. To ask that question is almost to answer it: it is generally obvious to separate a single component into two components that together perform the same function as the single component. . . . JCI’s decision to put a 'seal portion' between the hydraulic fluid and the 'piston,' as in claims 9 and 10, did not result in a unobvious modification of the prior art."

Metso Minerals Industries Inc., et. al. v. Astec Industries Inc., et. al., 2-10-cv-00951 (WIED December 4, 2012, Order) (Adelman, J.).