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PRECEDENTIAL: Stipulation Roadmap for Fintiv Factor Four

It has now been more than seven months since the PTAB designated Apple Inc. v. Fintiv, Inc., IPR 2020-00019, paper 11 (PTAB Mar. 20, 2020), as a precedential decision. Under this precedent, the PTAB applies a six factor,...more

Lights Out For Solar Cell Follow-On Petition

The PTAB denied institution of a follow on petition filed five months after an initial petition by the same petitioner, even though the two petitions were directed to different claims. The Board found no persuasive...more

Same or Similar Art Mutes IPR Petition on Medical Device Patent

35 U.S.C. § 325(d) gives the PTAB discretion to deny a petition for inter partes review when the same or substantially the same prior art or arguments were previously before the Office – including during original examination,...more

325(d) And Printed Publication Issues Doom Petition

The most persuasive IPR petitions offer fresh unpatentability theories never considered before. But petitions that simply repackage old issues often don’t gain traction. So, when you’re citing prior art that was before the...more

Precedential Opinion Panel On Printed Publications

Inter Partes review can only be based on prior art consisting of patents or printed publications. 35 USC 311(b). Patents are easy to spot because they are issued by a governmental authority of some sort, but whether something...more

No Motivation to Combine May Not End the Obviousness Inquiry

In Polygroup Limited MCO v. Willis Electric Company, Ltd., the Federal Circuit reversed and remanded the PTAB’s findings of patentability in light of several obviousness arguments presented by the petitioner, concluding that...more

Indefiniteness Again Leads To Unsuccessful IPR Challenge

The PTAB may institute IPR proceedings only on the basis of certain prior art that is potentially invalidating under § 102 (novelty) or § 103 (obviousness). The PTAB may not institute IPR on any other unpatentability grounds,...more

Petitioner’s Reply May Expand Presented Arguments and Address New Claim Constructions

On August 27, 2018, the Federal Circuit vacated and remanded the PTAB’s finding that claims 1-3, 6-9, and 12-14 of U.S. Patent No. 5,602,831 (“the ’831 Patent”) are not unpatentable under 35 U.S.C. § 103. See Ericsson Inc. v....more

Claim Constructions Under the Broadest Reasonable Interpretation Standard Must be Reasonable

On July 13, 2018, the Federal Circuit reversed the PTAB’s finding that claims 1-5 and 11 of U.S. Patent No. 8,651,118 (“the ’118 Patent”) are anticipated.by U.S. Patent No. 4,148,330 (“Gnaga”) and Japanese Application No....more

Use Caution When Considering Multiple IPRs Against a Single Patent

The recent PTAB order in IPR2017-01427 is a cautionary tale for petitioners considering multiple IPRs against a single patent. On May 11, 2017, Facebook and WhatsApp filed the ’1427 IPR petition challenging claims 1-8 of U.S....more

Not So Secondary: Overcoming Obviousness With Objective Indicia

On April 2, 2018, the PTAB issued a final written decision in Fox Factory finding that the petitioner failed to carry its burden in showing the instituted claims were unpatentable as obvious. Fox Factory, Inc. v. SRAM, LLC,...more

Unsupported Assertions: Expert’s Persuasive Authority Suffers Without Directly Engaging Claim Limitations

An expert asserting that a patent claim reciting different features than the prior art is nonetheless “equivalent” to the prior art must address and account for the recited limitations head-on, or otherwise lose persuasive...more

Anticipation Requires More Than A Reference That Discloses All The Elements

In Microsoft Corp. v. Biscotti, Inc., Nos. 2016-2080, -2082, -2083, 2017 WL 6613262 (Fed. Cir. Dec. 28, 2017), a divided Federal Circuit panel affirmed the Patent Trial and Appeal Board’s decision that Microsoft failed to...more

Federal Circuit Overturns PTAB Fact-Finding Regarding Conception of Invention

In IPR2014-01198, the PTAB found that the patent owner failed to prove that the patented invention was conceived prior to the date of the prior art, and thus concluded that the patent was unpatentable. The Federal Circuit...more

PTAB Requires Identification of Structure for Function for Means-Plus-Function Terms

In a decision dated August 17, 2017, the Board denied institution of Kingston Technology Company, Inc.’s petition requesting inter partes review of claims 1-3, 6-8, 11-15, 23-28, and 36-39 of U.S. Patent No. 6,088,802 (“the...more

Federal Circuit to PTAB – No 102 Gap Filling

In a precedential opinion dated March 14, 2017, the Federal Circuit reversed the PTAB, holding that in finding a claim anticipated under 35 USC § 102, the Board cannot “fill in missing limitations” simply because a skilled...more

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