The battle came down to the value of expert witness testimony; in a case with simple technology, not much.

ATMI relies on its expert to demonstrate a genuine issue of material fact regarding what the prior art teaches, citing Hodosh v. Block Drug Co., 786 F.2d 1136 (Fed. Cir. 1986) and Rockwell International Corp. v. United States, 147 F.3d 1358 (Fed. Cir. 1998).

In opposition, Praxair submits that although the parties did submit expert reports, the relatively simple technology at issue allowed the judge to recognize the teachings of the prior art and the scope of ATMI’s patents without assistance from experts.

Under certain circumstances, an expert’s opinion may illuminate disputes of fact, thus requiring a trial. Hodosh, 786 F.2d at 1142–43. Likewise, the trial court may not draw inferences to find a required disclosure in the prior art. Rockwell, 147 F.3d at 1366. Hodosh and Rockwell do not, however, stand for the proposition that any expert’s declaration will suffice to defeat summary judgment. Indeed, where a prior art reference plainly discloses a claim limitation, the court may recognize and apply that teaching on summary judgment. See Union Carbide Corp. v. Am. Can Co., 724 F.2d 1567, 1571–72 (Fed. Cir. 1984). “In many patent cases expert testimony will not be necessary because the technology will be ‘easily understandable without the need for expert explanatory testimony.’ ” Centricut, LLC v. Esab Group, Inc., 390 F.3d 1361, 1369 (Fed. Cir. 2004) (quoting Union Carbide, 724 F.2d at 1573).

For shoddy holding of the ball by the expert witness, ATMI is punted.

While ATMI presented an expert report disputing the teaching in the asserted prior art, the report lacks the detail necessary to avoid summary judgment. In particular, ATMI’s expert lacked logical continuity, leaving only a conclusory record to oppose summary judgment of obviousness. We find the district court’s decision well supported by the record, and agree that no issues of material fact remain. Each of ATMI’s asserted disputes regarding issues of material fact lack either substance or relevance.