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Sale of Domestic Industry Product Not Required Prior to Filing Complaint

The ITC recently indicated that 19 U.S.C. 1337(a)(2) does not require that a domestic industry product be sold before a complaint is filed for a domestic industry to exist. See Certain Road Construction Machines and...more

Clarified: Standing Requirements and Burden Shifting Framework in IPR Proceedings

Any person or entity may file an IPR proceeding to invalidate a patent, regardless of whether it faces a specific threat of infringement. An adverse decision in an IPR proceeding is appealable only to the Federal Circuit....more

Delay in Identifying Prior Art Prevents Their Addition to Notice of Prior Art

In a recent order, Administrative Law Judge Shaw denied in part the Respondents’ Motion to Supplement their Notice of Prior Art. In re Certain Strontium-Rubidium Radioisotope Infusion Systems, And Components Thereof Including...more

Even Unrebutted Experts Need To Do More Than Make Conclusory Assertions

In Diebold Nixdorf, Inc. v. ITC, the Federal Circuit reversed the ITC’s finding of a Section 337 violation based on the ITC’s reliance on unrebutted expert testimony. Diebold, No. 17-2553 (Fed. Cir. Aug. 15, 2018). The case...more

Relevant Public, Not General Public, When Determining Availability of Printed Publication

On July 27, 2018, the Federal Circuit reversed the PTAB’s finding that Petitioner GoPro, Inc. failed to establish the public availability of an alleged prior art printed publication. GoPro, Inc. v. Contour IP Holding LLC, __...more

ITC Makes It Easier for Complainants to Meet the Domestic Industry Requirement

In a recent decision, the Commission overruled the ALJ to clarify, and ultimately expand, the universe of investments that complainants can use to meet the economic prong of the domestic industry (“DI”) requirement. Certain...more

Federal Circuit Continues To Address Transitional IPR Appeals Post-SAS

When the Supreme Court issued its decision in SAS Institute regarding partial IPR institution, the PTAB estimated that there were several hundred pending IPRs in which the Board had instituted some, but not all, claims and/or...more

Some ITC Decisions Create Collateral Estoppel

While patent decisions from the ITC do not have collateral estoppel effects on later district court cases, other ITC decisions may create collateral estoppel. In a case of first impression, a district court recently ruled...more

The Supreme Court’s SAS Decision Is Already Affecting Pending Proceedings

On April 24, 2018, the U.S. Supreme Court issued its decision in SAS Institute Inc. v. Iancu, where the Court held that the Patent Trial and Appeal Board (PTAB) must issue a final written decision as to any patent claim...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

The Commission Doesn’t Rubber Stamp Even Highly Technical Claim Constructions

On February 14, 2018, the Commission affirmed ALJ Pender’s initial determination of non-infringement but based on modified grounds related to the construction of the claim term “single-molecule sequencing.” In re Certain...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

Is The PTAB Bound By A Previous Federal Circuit Claim Construction?

In previous posts, we have discussed whether the PTAB and the district courts can reach different conclusions on the same issue. In those instances, the Federal Circuit held they can, because the standards applicable at the...more

ALJ Precludes Reliance on New Domestic Industry Products

Following up on a previous post, Administrative Law Judge Bullock recently granted Respondents Fujifilm Holdings Corporation, Fujifilm Corporation, Fujifilm Holdings America Corporation, and Fujifilm Recording Media U.S.A.,...more

PTAB Denies PGR Petition Due To Related Application

By Dave Maiorana By now, most PTAB practitioners are familiar with 35 U.S.C. § 325(d), which gives the Board the authority to deny institution of a post-grant proceeding because the same or substantially the same prior art or...more

ALJ Denies Inequitable Conduct “Fishing Expedition”

In a recent order, Administrative Law Judge Lord denied Respondents CSL Behring LLC, CSL Behring GMBH, and CSL Behring Recombinant Facility AG (“CSL Behring”) motion to compel discovery from Complainants Bioverativ Inc.,...more

The Federal Circuit Criticizes A PTAB Partial Institution

The PTAB’s practice of partially instituting IPRs has been in the news lately, with Jones Day recently arguing against that practice at the Supreme Court on behalf of the SAS Institute (“SAS”). On December 5, 2017, the week...more

100-Day Pilot Program Proceedings Remain Rare

In two recent orders, the Commission denied respondents’ requests for entry into its Early Disposition Pilot Program (100-day Pilot Program). It has now been over two years since the ITC issued its proposed rulemaking for the...more

Diagrams Not Considered Source Code Under Modified Protective Order

In a recent Order, ALJ McNamara clarified that while diagrams drawn by an expert depicting the interplay and hierarchy of relevant code modules, inputs, and outputs of source code are to be treated as confidential business...more

PTAB Stays Reexamination in IXI Mobile (R&D) Ltd. v. Google LLC

In August 2016, Google petitioned for Inter Partes Review of U.S. Patent No. 7,552,124 (owned by IXI Mobile), asserting that claims 1–10 are unpatentable. In March 2017, the PTAB instituted the IPR as to claims 1–5, but...more

Secondary Considerations Win Again

As we have previously discussed (on February 1, March 1, March 30, and May 19), reliance on secondary considerations of non-obviousness has been hit or miss for patent owners trying to convince PTAB panels that the secondary...more

ALJ Essex Retires

ALJ Essex has retired from the ITC after a decade of service. News of his retirement was provided in notices issued this week by Chief ALJ Bullock in investigations previously assigned to ALJ Essex....more

PTAB Designates Portion Of Assignor Estoppel Opinion As Precedential

In October 2016, we posted about a Federal Circuit decision addressing whether assignor estoppel bars a party from filing an inter partes review petition. In Athena Automation Ltd. v. Husky Injection Molding Systems Ltd., the...more

No Stay of Remedial Orders Even After PTAB Finds Claims Unpatentable

The ITC has dealt a significant blow to the use of Inter Partes Review as a defense to a Section 337 investigation. In an order issued this week, the Commission denied a request to stay remedial orders that are currently on...more

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