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Institution Denied for Insufficient Publication Evidence

On October 29, 2024, BabyBjörn AB (“BabyBjörn”) filed two separate petitions for inter partes review (“IPR”) of U.S. Patent No. 11,786,055 (“the ’055 Patent”), which is assigned to The ERGO Baby Carrier, Inc. (“ERGO Baby”). ...more

INFORMATIVE: Acting Director Rescinds Institution Where Claims Held Invalid in District Court Case

On August 22, 2024, Hulu, LLC (“Hulu”) filed two separate petitions for inter partes review (“IPR”) of U.S. Patent No. 11,463,768 (“the ’768 Patent”), assigned to Piranha Media Distribution, LLC (“Piranha”). The ’768 Patent...more

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

Supreme Court Denies Petition Arguing for Preclusive Effects of PTAB Decisions Pending Appeal

On February 20, 2024, the Supreme Court denied Liquidia Technologies’ petition for a writ of certiorari to review a precedential Federal Circuit decision, United Therapeutics Corp. v. Liquidia Techs., Inc., 74 F.4th 1360...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

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

PTAB Denies Joinder To Settled IPR

On September 1, 2022, CommScope, Inc. (“CommScope”) filed a Petition for inter partes review (“IPR”) of claims 8–10, 15, 24–26, and 31 of U.S. Patent No. 8,462,835 (“the ’835 Patent”) in IPR2022-01443 (“the ’443 IPR”). The...more

Interim Procedure for Discretionary Denials Established

On June 21, USPTO Director Kathi Vidal issued a memorandum concerning the PTAB’s practice of determining whether to institute an AIA post-grant proceeding in view of the Fintiv factors. The memorandum is in part a result of...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

Invalidity Counter Against Unasserted Claim Does Not Implicate §315(a)

It is well-established that a counterclaim for invalidity in a district court litigation does not trigger the 35 U.S.C. § 315(a) bar. See 35 U.S.C. § 315(a)(3). See also our previous posts discussing strategies for...more

PGR Estoppel Applies to Unasserted Art

Due to the relatively low number of post-grant reviews (“PGR”) filed to date, not many district courts have spoken on the scope of PGR estoppel. In GREE, Inc. v. Supercell Oy, No. 2:19-cv-00071 (E.D. Texas), Magistrate Judge...more

Circumstantial Evidence Can Help You Satisfy The Importation Requirement…But Only Under The Right Circumstances

In a recent summary determination order, ALJ Bullock found that complainants cannot always rely on circumstantial evidence to satisfy the Section 337 importation requirement. Certain Height-Adjustable Desk Platforms and...more

PTAB Declines Institution After Discovery of Unnamed Real Party in Interest

To institute an inter partes review (IPR), the petition requesting the proceeding must be filed within one year of the petitioner or real party in interest (RPI) receiving a complaint alleging patent infringement. 35 U.S.C. §...more

ITC Imposes Fine for Violating Cease and Desist Order

In a recent Enforcement Initial Determination, ALJ Shaw held that Sony had violated previously issued cease and desist orders (“CDOs”) and determined that the appropriate penalty was a fine of $210,134 – Sony’s net profit...more

Federal Court Relies on PTAB Findings in Denying Section 101 Summary Judgment Motion

Despite the prohibition on patenting “abstract ideas” and the tendency of computer software claims to fall into that category, claims directed at improving faulty software systems may still be patentable if they encompass an...more

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