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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

Petitioner Prevails In Institution Decision Do-Over After Director Steps In

On November 6, 2023, the PTAB issued an decision instituting inter partes review of U.S. Patent No. 10,681,009 B2 (“the ’009 patent”) in Keysight Technologies, Inc. v. Centripetal Networks, Inc., IPR2022-01421, Paper 16 (PTAB...more

Director Demonstrates Ability to Review Non-Dispositive PTAB Determinations

On May 16, 2023, Director Katherine Vidal vacated a portion of a final written decision regarding real parties in interest (“RPIs”) in Unified Patents, LLC v. Memory Web, LLC, IPR2021-01413. Director Vidal held that the...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

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

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

The Board Declines To Apply Interference Estoppel

On June 14, 2022, the Board instituted Zynga Inc.’s (“Zynga”) petition for IPR against U.S. Patent No. 7,168,089 (the “’089 patent”), rejecting Patent Owner IGT’s argument that interference estoppel should preclude...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

Discovery Request Seeking Deposition Preparation Materials Denied

The Patent Trial and Appeal Board (“PTAB”) recently denied a Motion for Additional Discovery because the movant could not prove beyond mere speculation that the requested documents would be useful to show witness scripting....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

Take Care When Modifying the PTAB’s Default Protective Order

After an initial denial, the PTAB recently granted Unified Patents’ motions for entry of protective order and for seal in Unified Patents, LLC v. Electronics and Telecommunications Research Institute, IPR2020-01048, Paper 33...more

IPR Proceedings: Extrinsic or Intrinsic Evidence for Claim Construction?

In district courts’ claim construction analyses, intrinsic evidence is of paramount importance. Although extrinsic evidence “may be useful to the court,” it is considered “less significant” than the claim language,...more

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