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Federal Circuit: PTAB Decision of Invalidity Cannot Estop District Court Litigation on Different Claims from the Same Patent, Even...

The Federal Circuit recently refused to apply collateral estoppel to claims of a patent asserted in district court litigation based on a Patent Trial and Appeal Board (PTAB) decision finding similar claims from the same...more

Federal Circuit: Private Sale by Inventor Does Not Trigger Prior Art Exception Under the AIA

The Federal Circuit affirmed a Patent Trial and Appeal Board (PTAB) final written decision holding that the prior art exception of AIA Section 102(b)(2)(B) does not apply to a prior sale by an inventor when the sale is...more

PTAB Refuses to Ignore Reference Where Patent Owner Fails to Overcome Prima Facie Evidence of ‘Different Inventive Entity’

The Patent Trial and Appeal Board determined that a reference could be used as prior art because patent owner failed to provide sufficient evidence that the prior art’s disclosure was invented by all four named inventors, and...more

Federal Circuit Vacates and Remands District Court’s Fee Award Due to Consideration of Irrelevant 'Red Flags'

The Federal Circuit vacated a district court’s fee award because the district court considered certain information that was not relevant to the question of whether plaintiff’s case was exceptional. Specifically, the Federal...more

PTAB May Not Discretionarily Deny Institution Where Different Petitioners Do Not Share a 'Significant Relationship'

The Patent Trial and Appeal Board exercised its discretion under General Plastic to deny institution of a follow-on petitioner’s request for inter partes review despite determining that the petitioner did not have a...more

PTAB: Patent Drawings Without Precise Measurements May Be Relied Upon as Prior Art, but Only for What They Clearly Show

The Patent Trial and Appeal Board denied institution of an inter partes review petition because a prior art patent figure did not provide exact dimensions, and therefore could not meet the relevant claim limitation.  On...more

Delay in Correcting Disclosure of Real Parties-in-Interest not Procedurally Fatal to IPR Petition

The Patent Trial and Appeal Board instituted an inter partes review over patent owner’s objections that the petition did not timely identify all real parties-in-interest (RPI) and was filed by a phantom legal entity after...more

Defendants Ordered to Coordinate Pretrial Litigation in MDL Are Not Necessarily 'Significantly Related' to Support Discretionary...

The Director of the U.S. Patent and Trademark Office vacated and remanded a decision from the Patent Trial and Appeal Board discretionarily denying institution of an inter partes review petition. The Director concluded that...more

PTAB Institutes IPR Despite Delayed Sotera Stipulation

The Patent Trial and Appeal Board granted institution of inter partes review after petitioner submitted a Sotera stipulation to patent owner via email, several days after patent owner’s preliminary response. The board...more

PTAB: Dynamic Drinkware Written Description Requirement Inapplicable to Post-AIA Patents

The Federal Circuit held in Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015) that for a pre-AIA 35 U.S.C. § 102(e) prior-art reference to be entitled to a provisional application’s priority...more

District of Delaware Holds That IPR Estoppel Does Not Apply to Device Art

Federal Circuit Judge William Bryson, sitting by designation in the District of Delaware, ruled on summary judgment that inter partes review (IPR) estoppel does not apply to device art, even if the device is cumulative of...more

PTAB Rejects Argument of Alleged Master Plan to Circumvent IPR Time Bar

The Patent Trial and Appeal Board rejected a patent owner’s argument that the Board should exercise its discretion to deny a petitioner’s inter partes review (IPR) petition because Petitioner failed to name a time-barred real...more

Director Vacates PTAB’s Denial of Institution That Contradicted Federal Circuit Precedent on Anticipation and Written Description...

A Petitioner filed a request for rehearing and a request for Precedential Opinion Panel review after the Patent Trial and Appeal Board (PTAB or the “Board”) rejected its petition for post-grant review. The Director of the...more

Withholding Data That PTAB Would Deem Relevant to Patentability Supports Adverse Judgment in an IPR

The Patent Trial and Appeal Board (PTAB) granted Petitioner’s motions to sanction Patent Owner for failure to meet its duty of candor and fair dealing in five related inter partes review  proceedings. The PTAB found that...more

Courts Must Analyze Claims as a Whole to Determine Whether Independent Claims That Lack Written Description Preclude Assertion of...

The District Court for the District of New Jersey recently denied a defendant’s motion for summary judgment which sought to invalidate a dependent claim on preclusion grounds based on the PTAB’s invalidation of the related...more

PTAB Precedential Ruling: Expert Declaration Devoid of Supporting Evidence Dooms IPR Petition

The Patent Trial and Appeal Board recently rejected an inter partes review petition that relied on a conclusory and unsupported expert declaration. The expert’s written testimony, which repeated portions of the petition...more

Federal Circuit: Claim Amendments During IPR That Respond to Grounds of Unpatentability May Also Make Changes Unrelated to the IPR

In a recent decision, the Federal Circuit affirmed the PTAB’s policy of permitting claim amendments unrelated to the IPR proceedings when the amended claims also included amendments that respond to a ground of...more

PTAB Applies Director’s Guidance and Holds that Compelling Evidence of Unpatentability Precludes Fintiv Denial

In an IPR institution decision issued shortly after the USPTO issued interim guidance on discretionary denials, the PTAB held that the petition presented “compelling evidence of unpatentability,” foreclosing a Fintiv...more

PTAB Awards Priority for CRISPR-Cas9 Systems in Eukaryotic Cells to Broad Institute, MIT and Harvard

In its latest decision in a series of interferences related to the CRISPR gene-editing system, the Patent Trial and Appeal Board (PTAB) granted priority to The Broad Institute, MIT and Harvard (collectively, “Broad”) for...more

Federal Circuit Clarifies Scope of IPR Estoppel, Reversing Prior Shaw Decision

The Federal Circuit recently clarified that the scope of IPR estoppel in district courts includes prior art grounds that were raised or reasonably could have been raised in a petition for inter partes review (IPR), reversing...more

Cancellation of Independent Claims in IPR Does Not Estop Doctrine of Equivalents Arguments for Surviving Dependent Claims

A judge in the Eastern District of Virginia recently held that cancellation of independent claims in an inter partes review (IPR) did not preclude the plaintiff from asserting infringement based on the doctrine of equivalents...more

PTAB: Inadvertent Mistake in Analysis of Experimental Data that Substantially Impacts Proceeding Cannot be Corrected

The PTAB recently denied a motion to correct clerical mistakes under 37 C.F.R. § 42.104(c) because the corrections presented substantive new evidence that would have had a substantial impact on the proceedings and prejudiced...more

Due to “Apparent Loophole” in Statutory Framework, District Court Permits Invalidity Challenge that Does Not Foreclose Later IPR

When bringing a lawsuit for a declaratory judgment of non-infringement of a patent, careful pleading may allow plaintiffs to avoid the restrictions against later seeking inter partes review (IPR) of that patent, while also...more

Supreme Court Forecloses Judicial Review of PTAB’s Timeliness Determinations

- The Supreme Court ruled 7-2 in Thryv, Inc. v. Click-to-Call Technologies, LP, that the PTAB’s application of the one-year time limit for petitions for inter partes review, set out in 35 U.S.C. § 315(b), is not subject to...more

PTAB Designates Two Decisions as Precedential and One Decision as Informative, Clarifying Its Exercise of Discretion on...

The Patent Trial and Appeal Board (PTAB or Board) recently designated two decisions as precedential and one decision as informative, marking its first precedential and informative designations for 2020. In two of the...more

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