Quad Environmental Technologies Corp. v. Union Sanitary District

NEWMAN, Circuit Judge Quad Environmental Technologies Corporation appeals the summary judgment of the United States District Court for the Northern District of California, holding all the claims of the patent in suit invalid on the basis of obviousness.1 The district court did not reach the issues of infringement and inequitable conduct, deeming them mooted. We conclude that summary judgment was improvidently granted, based on errors of law. Since material disputed facts require resolution, we reverse the grant of summary judgment and remand for trial.