Federal Circuit Vacates PTAB Ruling for Maschio Gaspardo on Seed Drill Patent in Precision Planting Appeal

Precision Planting LLC appealed the Patent Trial and Appeal Board's final written decision in IPR2024-00008, which held claims 1-5, 7-14, and 16 of U.S. Patent No. 8,770,121 not unpatentable. The opinion says Maschio Gaspardo S.p.A. owns the patent and that Precision Planting petitioned for review after Maschio sued it for patent infringement (Op. 1-2, 4). On appeal, Precision Planting challenged only the Board's ruling that claims 1-3, 7-12, and 16 would not have been obvious over Amazone, Fiorido, VenHuizen, and applicant-admitted prior art (Op. 4-5).

The claims

Representative claim 1 recites a seed distribution element for precision pneumatic seed drills with a motor-driven sowing disc, a housing with fixed and movable portions, a seal on the movable portion, and "a thrust-bearing element of the sowing disc, which thrust-bearing element is supported rotatably in the movable portion in order to withstand at least some of the axial load produced by the disc on the seal" (Op. 3-4).

What the court held

Writing for a panel of Chief Judge Moore and Circuit Judges Dyk and Taranto in Precision Planting LLC v. Maschio Gaspardo S.p.A., No. 2025-1809 (Fed. Cir. Oct. 30, 2026) (nonprecedential), Chief Judge Moore held that there is "no substantial evidence supporting the Board's finding that Fiorido fails to disclose the thrust-bearing element claimed in the '121 patent" (Op. 6). The court said contact between Fiorido's driving disk (31) and disk (13) is "clearly depicted in Fiorido's Fig. 2," and it declined to accept the contrary testimony of Maschio's expert as substantial evidence (Op. 7-8, 10).

The court did not reach Precision Planting's challenges to the Board's motivation-to-combine analysis, and held that an alternative obviousness theory not relying on Fiorido's thrust-bearing disclosure was forfeited (Op. 11-12 and n.4). It instructed the Board on remand to apply the principles of KSR International Co. v. Teleflex Inc., 550 U.S. 398 (2007) (Op. 12). The judgment: "VACATED AND REMANDED," with costs to Precision Planting (Op. 12).