Engate, Inc. v. Esquire Deposition Services (N.D. Ill. 2004)
In a patent infringement suit over Engate’s patented real-time transcription service technology, the District Court dismissed the defendant’s unfair competition counterclaim and granted in part defendant’s summary judgment of invalidity. The court looked to instances of real-time transcription in some courtrooms as evidence of public use sufficient to invalidate some of the claims.