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PTAB Pendulum Swings in Favor of Discretionary Denial

Recent developments at the USPTO suggest a significant shift in favor of the PTAB exercising discretionary denial and uncertainty on behalf of parties to PTAB proceedings.  ...more

Director Review: PTAB Must Articulate Bases for Section 325(d) Denial

Director Vidal recently vacated the Patent Trial and Appeal Board’s (PTAB) decision to deny institution of three petitions for inter partes review (IPR), citing insufficient explanation for denial under 35 U.S.C. §325(d). ...more

“Eleventh Hour” Sotera Stipulation Sufficient to Avoid Denial

The PTAB recently declined to exercise its discretion to deny IPR, instituting review in BMW of North America, LLC v. NorthStar Systems LLC, IPR2023-01017, Paper 12 (Dec. 8, 2023). There, the PTAB held that (1) a Sotera...more

Insufficient Arguing Below Causes Forfeited Review Above

Absent exceptional circumstances, the Federal Circuit will generally not consider arguments that a party failed to present in the tribunal under review. In Netflix, Inc. v. DivX, LLC, the Federal Circuit held that IPR...more

Federal Circuit Clarifies Important IPR Estoppel Issues

Under 35 U.S.C. § 315(e)(2), a patent challenger in an inter partes review (IPR) that reaches a final written decision is estopped from arguing in a district court or the ITC that the challenged patent is invalid based on...more

PTAB Denies Authorization to Submit Exhibit For Not Following the Rules

The PTAB recently granted a joint request to expunge an exhibit and contemporaneously denied the Patent Owner’s request for authorization to file a Motion for Leave to Submit the same exhibit in Bausch & Lomb Inc. v....more

A Petitioner’s Guide: Navigating Uncertainty on PGR Eligibility

Samsung Electronics Co. (“Samsung”) recently faced the issue of determining whether U.S. Patent No. 11,163,823 (“the ‘823 patent”) is a pre- or post-AIA patent. Hedging its bets, Samsung concurrently filed two petitions—one...more

Ex Parte Reexamination Barred Based on Earlier IPR

On November 16, 2022, the United States Patent and Trademark Office (“PTO”) vacated a reexamination proceeding because the patent challenger relied on unpatentability grounds that reasonably could have been raised in an...more

Director Vidal Orders Sua Sponte Review (Again) in OpenSky v. VLSI

In the latest development of OpenSky Industries v. VLSI Technology, USPTO Director Kathi Vidal has ordered sua sponte Director review of a PTAB panel’s decision on remand to institute OpenSky’s IPR challenge to a patent owned...more

USPTO Releases Study On Fintiv Denials

The USPTO released a study in June 2022 that analyzed the prevalence of Fintiv denials occurring between January 1, 2019 and December 31, 2021. The Study focused on data illustrating how often patent owners raised parallel...more

Interim Fintiv Guidance Discussed in PTAB Boardside Chat

During the Patent Trial and Appeal Board (“PTAB”) Boardside Chat on July 7, 2022, discussion focused on Director Katherine Vidal’s interim guidance on discretionary denials under the Board’s precedential Apple v. Fintiv...more

PGR Estoppel Continues to be Broad and Onerous

An ITC Administrative Law Judge (ALJ) recently issued an initial determination holding that PGR estoppel prevented GMG Products LLC (Respondent) from raising two prior-art products in the ITC....more

Deposition Exhibits Allowed With Sur-Replies (Sometimes)

Under the Board’s rules, a patent owner gets to have the last word in a PTAB proceeding by filing a sur-reply to the petitioner’s reply.  Sur-replies may only respond to arguments raised in the reply, and the “sur-reply … may...more

District Court Highlights Prior PTAB Invalidation

On May 26, 2021, the United States District Court for the Western District of Washington denied both defendant Valve Corporation’s (“Valve”) motion for judgment as a matter of law or a new trial, and plaintiff Ironburg...more

Mid-Year Review of Key Trade Secret Decisions

A trade secret is any information used in one's business that derives independent economic value from not being generally known. Unlike patents, trade secrets are protected indefinitely for as long as they remain a secret....more

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