Attorney advertising. This article is general information, not legal advice.

Patent drawings often get less attention than the written description. Engineers sketch them, drafters tidy them up, and everyone moves on to the claims. A new Federal Circuit decision about seed-drill technology shows why that habit is risky on both sides of a patent dispute: what a figure clearly shows can count as prior art, even if no one explained it in words.

On October 30, 2026, in Precision Planting LLC v. Maschio Gaspardo S.p.A., No. 2025-1809, the U.S. Court of Appeals for the Federal Circuit vacated part of a Patent Trial and Appeal Board decision and sent the case back for a new obviousness analysis. Chief Judge Moore wrote the opinion for a panel that also included Judges Dyk and Taranto. The decision is nonprecedential, so it doesn’t bind future panels.

The patent and the challenge

The patent, U.S. Patent No. 8,770,121, is owned by Maschio Gaspardo and relates to precision pneumatic seed drills, which control how seeds are spaced along a sowing track. The claimed seed-distribution element uses a motor-driven sowing disc between a fixed and a movable housing portion, with suction holding seeds on the disc until they’re released. The key feature on appeal was a “thrust-bearing element” supported in the movable portion to withstand at least some of the axial load the disc puts on a seal.

After Maschio sued Precision Planting for infringement, Precision petitioned for inter partes review (IPR2024-00008). The Board held all the challenged claims not unpatentable. On appeal, Precision challenged only the Board’s ruling that claims 1–3, 7–12, and 16 would not have been obvious over a combination of references that included a European patent publication known as Fiorido.

What Fig. 2 showed

The dispute came down to whether Fiorido’s driving disk touched its seed disk. If it did, the parties agreed a skilled person would understand the driving disk to bear some axial load, which is the job of the claimed thrust-bearing element. The Board found Fiorido didn’t disclose that element, in part because Fiorido’s text never expressly said the two disks were in contact.

The Federal Circuit held that finding wasn’t supported by substantial evidence, because the contact is “clearly depicted in Fiorido’s Fig. 2.” The court cited In re Mraz, a 1972 decision explaining that “the teachings of patent drawings, even as to features unexplained by the specification,” can be dispositive in an obviousness analysis. Silence in the text didn’t erase what the drawing showed.

The court also rejected the Board’s other reasons. Separate contact between a sealing ring and the disk in the same figure did nothing to disprove contact by the driving disk. And an alternative embodiment where the driving disk might not bear thrust couldn’t cancel out the embodiment drawn in Fig. 2.

Expert testimony can’t contradict a clear figure

The patent owner’s expert suggested Fig. 2 shouldn’t be taken at face value. The court found nothing in that testimony that a reasonable mind could accept as a basis to disregard the contact shown. Relying on earlier cases, it repeated that the court “must disregard the testimony of an expert that is plainly inconsistent with the record,” and that conclusory expert testimony can’t create a factual dispute about what figures clearly show.

The court vacated the obviousness ruling on the disputed claims and remanded. It didn’t decide whether the claims are obvious. The Board will redo that analysis, including whether a skilled person would have combined the references, now treating Fiorido as disclosing a thrust-bearing element.

Takeaways for Iowa ag-equipment and manufacturing innovators

• Your drawings are part of what you disclose. Once published, a figure can be used against later patents, including your own, for whatever it clearly shows.
• Draft figures deliberately. Contact, gaps, and part relationships in a drawing may be read literally. Make sure figures match what you mean to show and that the text describes important features.
• Read the figures in freedom-to-operate and invalidity work. A reference that seems silent in its text may still teach a feature in its drawings. Foreign publications count too.
• Don’t count on an expert to explain away a picture. Testimony that contradicts what a figure plainly depicts may be given no weight.
• Remember that a remand isn’t a final answer. This ruling reopens the obviousness question; it doesn’t decide it.

For more on how prior art can turn up in unexpected places, see our Syngenta v. UPL post. Our patents page covers drafting, searching, and the application process.

Source: the Federal Circuit’s opinion in Precision Planting v. Maschio Gaspardo (nonprecedential).

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Jason Sytsma helps Iowa manufacturers, agricultural-equipment companies, and inventors decide what to protect and how to draft and claim it. Learn more on the About Jason page and the firm bio.

Contact the office to request a consultation. Any engagement is subject to conflicts review, an engagement agreement, and applicable professional-responsibility rules. This article is attorney advertising and is intended for general educational purposes only; it is not legal advice and does not create an attorney-client relationship. Results vary, and past experience does not guarantee a particular outcome.