3D Systems, Inc. v. Aarotech Laboratories, Inc
In 3D Systems, Inc. v. Aarotech Laboratories, Inc., 160 F.3d 1373 (Fed. Cir. 1988), the Court held that price quotations could constitute an offer for sale.
In Aarotech, the accused infringers sent price quotations for an allegedly infringing device directly targeted at potential customers. Id. at 1376.
Noting that such price quotations generated interest in a potential infringing product to the commercial detriment of the rightful patentee, the Court held that the price quotations constituted an offer for sale. Id. at 1379.