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The Federal Circuit Expands Scope of Domestic Industry Requirement in Lashify

In Lashify v. ITC, the Federal Circuit held that the economic prong of the domestic industry requirement, which is a precondition for obtaining International Trade Commission Section 337 relief, can be satisfied with...more

PTAB Denies Motion for Joinder After Unsuccessful District Court Invalidity Challenge

On June 6, 2024, Shenzhen Waydoo Intelligence Technology Co., Ltd. (“Waydoo”) filed a petition for inter partes review (“IPR”) of U.S. Patent No. 9,359,044 (“the ’044 Patent”) (“IPR998”), assigned to MHL Custom, Inc. (“MHL”)....more

Imprecise Claim Charts and Improper Incorporation By Reference Result in Institution Denial

On March 23, 2024, Nearmap US, Inc. (“Nearmap”) filed a petition for inter partes review (“IPR”) of U.S. Patent No. 10,671,648 (“the ’648 Patent”) (“IPR716”), assigned to Eagle View Technologies, Inc. (“Eagle View”). The...more

Institution Denied for Failure to Show Disclosure in Provisional Application

On December 1, 2023, Intelligent Wellhead Systems, Inc. (“Intelligent”) filed a petition for inter partes review (“IPR”) of U.S. Patent No. 11,401,779 (“the ’779 Patent”) (“IPR256”), assigned to Downing Wellhead Equipment,...more

PTAB Institutes IPR on Compelling Merits, Despite Other Fintiv Factors Favoring Denial

On October 27, 2023, Inergy Technology, Inc. (“Inergy”) filed concurrent petitions for inter partes review (“IPR”) of U.S. Patent Nos. 7,629,634 (“the ’634 Patent”) (“IPR093”) and 7,812,409 (“the ’409 Patent”) (“IPR094”),...more

Petition Denied for Lacking Section 112(f) Construction and Fintiv

On March 7, 2024, the PTAB denied institution in 10x Genomics, Inc. v. President and Fellows of Harvard College, IPR2023-01299, Paper 15 (PTAB Mar. 7, 2024) (“Decision”). The PTAB denied institution on two separate grounds:...more

PTAB Issues Sanctions for Attempted Extortion During “Settlement Negotiations”

Director Vidal recently issued sanctions against OpenSky Industries (“OpenSky”) for attempted extortion during settlement negotiations and abuse of the IPR process for US Patent 7,725,759 and awarded $413,264.15 to VLSI...more

2023 Annual Review: Key U.S. Trade Secret Developments

On January 5, 2023, President Biden signed the Protecting American Intellectual Property Act of 2022 (“PAIPA”) into law. PAIPA requires that the President submit an annual report identifying and describing any “significant...more

Narrow Stipulation Results in Fintiv Denial

On March 31, 2023, Zhuhai CosMX Battery Co., Ltd. (“Zhuhai”) filed a petition for inter partes review (“IPR”) of claims of U.S. Patent No. 11,329,352 (“the ’352 Patent”), assigned to Ningde Amperex Technology Ltd....more

PTAB Not Required to Decode Petitioner Arguments

In a precedential opinion, the Federal Circuit affirmed two Patent Trial and Appeal Board (“PTAB”) patentability decisions, holding that the PTAB did not abuse its discretion by not addressing arguments not clearly presented...more

PTAB Applies General Plastic Factors to Serial Petitions Seeking Joinder

In February 2023, T-Mobile USA, Inc. (“T-Mobile”) filed petitions requesting four inter partes reviews (“the T-Mobile IPRs”)—two of which challenged U.S. Patent No. 8,630,234 and two of which challenged U.S. Patent No....more

PTAB Clarifies Claim Preclusion Standards

On June 2, 2023,the PTAB held the standard enunciated in Astoria Federal Sav. & Loan Ass’n v. Solimino, 501 U.S. 104 (1991) applies to claim preclusion determinations. This was yet another decision in the ongoing battle...more

Director Determines Petitioner Not Expected to Anticipate § 325(d) Argument

Director Vidal recently vacated a decision denying institution of an inter partes review (“IPR”) to allow Google, the Petitioner, to brief whether discretionary denial was warranted under Section 325(d) in view of a European...more

Christmas Vacate-tion—Petitioners Allowed to Raise Fair Extensions of Petition Arguments

Willis Electric Co., Ltd. (“Willis Electric”) owns U.S. Patent No. 10,222,037 (the “’037 Patent”), titled “Decorative lighting with reinforced wiring.” The ’037 Patent claims a decorative lighting design involving a strand...more

Fintiv Revisited—District Court Transfer Results in Institution Reversal

In November 2020, Google LLC filed two petitions requesting an inter partes review of the claims of Ikorongo Technology LLC (“Ikorongo”) owned U.S. Patent No. 8,874,554 (“the ’554 patent”)....more

Prior Art Wanted—Cash Reward

Recently, Cloudflare Inc. succeeded in convincing the PTAB to institute in IPR2021-00969 against a Sable Network, Inc.’s patent directed toward data flow. While the institution itself is not out of the ordinary—the...more

President Biden Selects District of Delaware Chief Judge Stark For Federal Circuit

President Biden has selected Leonard P. Stark—Chief Judge of the U.S. District Court for the District of Delaware—to be the next member of the Federal Circuit, filling the vacancy that will be left behind when Judge Kathleen...more

ALJ Severs Investigation for Efficient Adjudication Pursuant to 19 C.F.R. § 210.14(h)

In a recent decision, ALJ Cheney determined that severance of an investigation was necessary for efficient adjudication of the issues raised in the Complaint. Certain Light-Emitting Diode Products, Systems, and Components...more

ITC Grants Summary Determination Against Defaulting Respondents and Issues GEO

In another example of why defaulting at the ITC can be a dangerous strategy, the ITC recently found all eight named respondents in default and concluded a general exclusion order (GEO) was the appropriate remedy. Since the...more

Product Prototype Built Abroad Satisfies Domestic Industry Requirement

On February 14, 2019, the U.S. International Trade Commission (“ITC”) issued an Initial Determination (“ID”) in the matter of Certain Road Construction Machines and Components Thereof, Inv. 337-TA-1088. In the ID, ALJ Lord...more

ITC Grants General Exclusion Order for Section 337 Violations

A recent initial determination (“ID”) from the ITC resulted in a general exclusion order for products infringing several patents belonging to Complainant National Products Inc. (“NPI”). Certain Mounting Apparatuses For...more

ITC Updates Its Rules of Practice and Procedure

Late last week, the International Trade Commission (“ITC”) finalized changes to its rules, which changes were first proposed in late 2015. The new rules are expected to be published in the Federal Register in early May 2018...more

STRONGER Patents Act Being Introduced to the U.S. House of Representatives

On March 20, 2018, Reps. Steve Stivers (R-Ohio) and Bill Foster (D-Ill.) announced in an article that they would introduce the STRONGER Patents Act to the U.S. House of Representatives. More formally referred to as The...more

Inventorship, Ownership, and Standing Issues May Be Too Complex For 100-Day Pilot Program

In a recent order, the Commission again declined to institute an Early Disposition Pilot Program (100-day Pilot Program), this time citing the complexity of the issues raised in the request. In the Matter of Certain...more

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