Federal Circuit Clarifies Scope of Pre-America Invents Act On-Sale Bar in Crown Packaging Decision

On Dec. 10, 2024, the U.S. Court of Appeals for the Federal Circuit issued a precedential decision in Crown Packaging Technology, Inc. v. Belvac Production Machinery, Inc. reversing a district court’s ruling by finding that a pre-critical date agreement triggered pre-America Invents Act (AIA) U.S.C. Section 102(b)’s on-sale bar. Specifically, the court held that a “quotation” letter with all the hallmarks of a commercial offer to sell could trigger the on-sale bar and clarified that the pre-AIA Section 102(b)’s “in this country” limitation pertains to the location of the offer, not the product’s eventual destination.