Crown Packaging v. Belvac: On-Sale Bar Reversal Reshapes Can Manufacturing Patent Dispute

Introduction

In a significant reversal spanning nearly seven years of litigation, the U.S. District Court for the Western District of Virginia entered final judgment in favor of Belvac Production Machinery, Inc. on January 27, 2025 — vacating its own prior summary judgment ruling after the Federal Circuit intervened. The case, Crown Packaging Technology, Inc. and Carnaudmetalbox Engineering, Ltd. v. Belvac Production Machinery, Inc. (Case No. 6:18-cv-00070), centered on four U.S. patents covering high-performance metal forming machinery used in beverage can manufacturing.

The Federal Circuit’s December 2024 decision — 122 F.4th 919 — applied the on-sale bar under 35 U.S.C. § 102(b), invalidating the district court’s earlier finding and ultimately collapsing the plaintiffs’ infringement claims against the Belvac necker machine. For patent practitioners and R&D leaders operating in precision manufacturing, this outcome delivers a pointed reminder: pre-filing commercial activity can be fatal to patent enforceability, regardless of how sophisticated the technology or how large the portfolio.

Case Overview

The Parties

The Patents at Issue

Four U.S. patents were asserted, all directed to innovations in can-forming machinery:

• • US7,770,425 B2 (App. No. 12/108,926)
• • US9,308,570 B2 (App. No. 14/070,954)
• • US9,968,982 B2 (App. No. 15/088,691)
• • US10,751,784 B2 (App. No. 15/928,984)

The patents collectively cover methods and apparatus for necking two-piece aluminum beverage cans — a process critical to achieving the narrowed-top profile of standard beverage containers. The claims encompass tooling geometry, machine throughput optimization, and forming precision relevant to high-volume commercial production.

The Accused Product

The accused product was **the Belvac necker**, a commercial machine used in the production of two-piece aluminum beverage cans. Given Belvac’s dominant market presence in can-line equipment, the commercial stakes extended well beyond a single product line.

Legal Representation

Plaintiffs were represented by Baker & Hostetler LLP and Gentry Locke Rakes & Moore LLP, with a ten-attorney team including Daniel J. Goettle, Jeffrey Lesovitz, and Robert Patrick Leeson. Defendant Belvac was represented by McGuireWoods LLP, with counsel including Brian Charles Riopelle, David Evan Finkelson, and Matthew George Rosendahl.

Litigation Timeline & Procedural History

Filed on July 9, 2018, in the Western District of Virginia, this case ran for an exceptional 2,394 days — approximately 6.5 years — before final disposition on January 27, 2025. The extended duration reflects the procedural complexity that frequently accompanies multi-patent manufacturing disputes, including claim construction proceedings, summary judgment practice, and Federal Circuit appellate review.

A pivotal procedural milestone was the district court’s grant of summary judgment in favor of the plaintiffs on the issue of no on-sale bar under 35 U.S.C. § 102(b) (Dkt. 125), memorialized in Order Dkt. 214. This ruling, favorable to Crown Packaging, appeared to clear a significant validity hurdle.

However, the Federal Circuit reversed that ruling in its December 10, 2024 decision (2024 WL 5049205), directing the district court to enter judgment for Belvac on the on-sale bar issue. The district court complied with a final order on January 27, 2025, vacating its prior ruling and closing the case with judgment for the defendant.

📎 Case docket available via PACER. Patents searchable through the USPTO Patent Full-Text Database.

The Verdict & Legal Analysis

Outcome

Judgment was entered in favor of Defendant Belvac Production Machinery, Inc. The district court vacated its previously granted summary judgment for the plaintiffs and entered final judgment for Belvac based on the Federal Circuit’s controlling decision. No damages were awarded to plaintiffs. The case was stricken from the court’s active docket.

The On-Sale Bar: Core Legal Reasoning

The dispositive issue was the on-sale bar under 35 U.S.C. § 102(b), which bars patent protection for inventions that were “on sale” more than one year before the effective U.S. filing date. The Federal Circuit, in Crown Packaging Technology, Inc. v. Belvac Production Machinery, Inc., 122 F.4th 919 (Fed. Cir. Dec. 10, 2024), found that the relevant patented subject matter had been commercially offered or sold prior to the applicable critical date — triggering the statutory bar and rendering the asserted claims invalid.

The district court had previously concluded the opposite — that no on-sale bar applied — and granted summary judgment to the plaintiffs on this threshold validity question. The Federal Circuit’s reversal underscores how courts scrutinize pre-filing commercial activity, including offers for sale, commercial arrangements, and prototype transactions, even in complex capital equipment markets where development cycles and commercialization timelines are lengthy.

Legal Significance

The Federal Circuit’s decision in 122 F.4th 919 carries notable weight for several reasons:

1. Affirms strict on-sale bar application in capital equipment sectors. Industrial machinery manufacturers often engage in early customer demonstrations, pilot installations, or pre-production agreements. This case confirms such activity can trigger § 102(b) invalidity even when formal commercial launch occurs later.
2. Post-Helsinn doctrine reinforcement. Following the Supreme Court’s 2019 ruling in Helsinn Healthcare S.A. v. Teva Pharmaceuticals USA, Inc., 586 U.S. 123 (2019), which confirmed the on-sale bar survives the AIA, the Federal Circuit continues to apply rigorous pre-filing scrutiny.
3. Summary judgment reversal risk. The case illustrates that district court summary judgment victories on validity can be fragile when commercial activity timelines are contested — a lesson for litigation strategy at both the trial and appellate levels.

Industry & Competitive Implications

The beverage can machinery sector is a concentrated, high-value market dominated by a limited number of global equipment suppliers. A sustained patent dispute between Crown Packaging — a major packaging innovator — and Belvac — a premier can-line machinery manufacturer — signals the competitive sensitivity around necking technology, tooling advances, and can-line efficiency improvements.

The ultimate invalidation of Crown’s asserted patents via the on-sale bar removes what would have been a significant IP barrier in this space. For Belvac, the judgment affirms its freedom to continue commercializing its necker product line without licensing exposure on these specific patents. For Crown Packaging, the outcome represents a strategic setback in efforts to monetize its can-forming IP portfolio against a key equipment competitor.

More broadly, this case reflects an ongoing trend in manufacturing patent litigation: validity, not infringement, is increasingly the decisive battleground. As patent assertion becomes more common in industrial sectors, defendants are successfully leveraging § 102 prior art bars — including the on-sale bar — to neutralize even multi-patent portfolios.

Companies in adjacent sectors — aerosol packaging, food can manufacturing, and metal forming equipment — should monitor licensing postures and FTO landscapes in light of this outcome.

Related reading: Helsinn Healthcare S.A. v. Teva Pharmaceuticals USA, Inc., 586 U.S. 123 (2019) | Federal Circuit opinion index at USPTO