The Federal Circuit held that selling a product made by a secret process starts the on-sale clock against a later patent on that process — and the America Invents Act did nothing to change it.
The Federal Circuit held that a slide poster displayed at a scientific meeting can be prior art under §102(b) even though it was never distributed or indexed in any library.
The Supreme Court held that a confidential commercial sale to a third party can place an invention 'on sale' under the AIA, just as it did under the prior statute.
The Supreme Court replaced the Federal Circuit's vague 'substantially complete' standard with a two-part on-sale-bar test that can start the clock before a prototype ever exists.
