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Far-Reaching Effect of IPR Estoppel Dooms Invalidity Defense Based on Prior Art Product

Chief Judge Stark granted a patent owner’s motion for summary judgment of inter partes review (IPR) estoppel, holding that obviousness defenses based on a prior art product could not be asserted because a prior art...more

Calling a Printed Publication a “System” is Not Enough to Avoid IPR Estoppel

A Central District of California judge recently granted summary judgment of no obviousness based on inter partes review (IPR) estoppel because the only prior art references used to challenge patent validity could have been...more

Prior Art That Was Considered but Not Relied Upon by an Expert is Fair Game for Discovery in IPRs

In inter partes review (IPR) proceedings of patents relating to printer technology, the Patent Trial and Appeal Board (PTAB) granted Patent Owner’s motion to compel testimony over Petitioner’s arguments that the information...more

Challenge to a Named Inventor’s Credibility on Case-Dispositive Issue Warrants Live Testimony in IPR

The Patent Trial and Appeal Board allowed live testimony in MPOWERED INC. v. LuminAID Lab, LLC, IPR2018-01524, on November 1, 2019, where a panel granted Patent Owner’s Motion for Live Testimony from a named inventor of the...more

Invalidity Defenses Will Not Be Stricken at Pleading Stage Despite Defendant’s Earlier PGR Petition

A district court has denied a patent owner’s motion to strike wholesale a defendant’s affirmative defense of invalidity. The key issue in the motion to strike was the application of the estoppel provision of 35 U.S.C. §...more

PTAB Orders Production of Raw Data and Instructions Underlying Test Results

The Patent Trial and Appeal Board (PTAB) recently issued an Order that illustrates the circumstances in which a party may obtain additional discovery in an inter partes review (IPR). In Apple Inc. v. Singapore Asahi Chemical...more

Patent Owner Precluded from Asserting in Litigation Claims Obtained Through Ex Parte Reexamination

A district court has denied a request to amend patent infringement contentions to add claims obtained through ex parte reexamination after the case had been substantially narrowed through a parallel inter partes review (IPR)...more

Forum Selection Clause, on Its Own, Does Not Bar PTAB from Instituting IPR Petition

The Patent Trial and Appeal Board has rejected a patent owner’s argument that a forum selection clause found in a Non-Disclosure Agreement (NDA) barred the Board from instituting a petition for inter partes review...more

Lack of Efficacy Data in Prior Art Dooms PTAB’s Unpatentability Finding for Method of Cancer Treatment Claims

The Federal Circuit recently overturned the Patent Trial and Appeal Board’s (PTAB) determination that claims covering a cancer treatment method were obvious. The patent at issue is directed to a method of treating...more

Misconduct During IPR May Trigger an Award of Attorneys’ Fees in Related District Court Litigation

A magistrate judge determined that a prevailing party in a district court litigation could be entitled to an award of attorneys’ fees based solely on conduct during an inter partes review (IPR) proceeding. In September...more

No Estoppel in District Court on Prior Art that Differs Substantively—and in a Manner Germane to Invalidity—from that Asserted in...

A Central District of California judge has clarified his prior ruling on summary judgment that estoppel under 35 U.S.C. § 315(e)(2) that applies to certain obviousness invalidity grounds raised by Defendants. In the prior...more

Withdrawal of Petitioner from IPR Proceeding All But Ensures Success in Contingent Motion to Amend

On remand from the Court of Appeals for the Federal Circuit, the Patent Trial and Appeal Board granted patent owner’s motion to amend on the basis that the totality of the record did not demonstrate by a preponderance of the...more

PTAB: Informal Delivery of Complaint Does Not Start One-Year Clock for Filing IPR

A Patent Trial and Appeal Board (PTAB or Board) panel has determined that emailing a proposed amended complaint is not “service of a complaint” under 35 U.S.C. § 315(b). On January 23, 2018, Aristocrat Technologies, Inc....more

PTAB Finds Good Cause for Staying Ex Parte Reexamination in Light of Parallel IPR

A panel at the Patent Trial and Appeal Board (PTAB) recently considered whether to stay an ex parte reexamination proceeding where the patent was also the subject of a parallel inter partes review (IPR). On September 11...more

Nearly Identical Petitions Fail Under Both Post-Grant Review and Inter Partes Review Standards

The Patent Trial and Appeal Board (PTAB) has denied a petitioner’s request for inter partes review (IPR) finding that petitioner failed to demonstrate a reasonable likelihood of prevailing with respect to at least one...more

PTAB: Reexamination Does Not Reset the One-Year Deadline For Filing a Petition for Inter Partes Review

The Patent Trial and Appeal Board has denied a Petitioner’s request for institution of inter partes review (IPR) of claims that were added during ex parte reexamination because it found the IPR petitions were time-barred...more

Federal Circuit: Skepticism of FDA Supports Finding of Nonobviousness and Patent Eligibility Not Within Scope of Appeal of an IPR

The Federal Circuit has affirmed a decision by the Patent Trial and Appeal Board finding nonobvious the claims of U.S. Patent No. 7,772,209 (the “’209 Patent”), which are directed to a method of treating cancer. The claims...more

PTAB: Federal Circuit’s Click-to-Call Holding Applies to Statutory Bar Under 35 U.S.C. § 315(a)

The Patent Trial and Appeal Board (the “Board”) vacated its institution decision and terminated an inter partes review (IPR) filed by Mylan Pharmaceuticals, Inc. (“Mylan”) based on Mylan’s prior counterclaim seeking a...more

Bar to File IPR Triggered by Declaratory Judgment Action, Even if Complaint Was Dismissed Without Prejudice

In Ruiz Food Products, Inc. v. MacroPoint LLC, the Patent Trial and Appeal Board (PTAB) considered whether the time-bar provision of 35 U.S.C. § 315(a)(1) was triggered when a real party-in-interest had previously filed an...more

PTAB Has Authority to Modify Initial Institution Decision in Light of SAS

In a recent final written decision, the Patent Trial and Appeal Board (PTAB) has determined that it was not unlawful for it to modify its institution decision following the SAS Supreme Court case. In the PTAB proceeding,...more

PTAB Denies Motion to Excuse Late Filing of Exhibits to IPR Petition

The Patent Trial and Appeal Board (PTAB) has denied a petitioner’s motion to excuse the late filing of the exhibits to its petition for inter partes review (IPR). The PTAB found that the petitioner had failed to show good...more

Evidence of Failed IPR Precluded When Validity No Longer at Issue

The Southern District of New York has granted a motion in limine precluding evidence of Defendant’s failed inter partes review (IPR) petition. The parties to the lawsuit are in the business of manufacturing and selling...more

PTAB Denies Request to Cross-Examine Experts Because Declarations Were Prepared for Other Proceedings and Were Not “Critical”...

In an ongoing inter partes review (IPR) proceeding, the Patent Trial and Appeal Board (the “Board”) denied Petitioner Nestlé Healthcare Nutrition, Inc.’s request to cross examine two expert witnesses after Patent Owner...more

Lift of Stay Disallowed by District Court Post-SAS in View of PTAB’s Final Written Decision Lacking Non-Instituted Claims

The Delaware District Court issued an order on June 7, 2018 denying a party’s motion to lift a stay following the Patent Trial and Appeal Board’s (PTAB) final written decision in a parallel inter partes review (IPR)...more

References Introduced During IPR Proceeding Not Necessarily New Evidence to Which Patent Owner Had No Opportunity to Respond

On May 14, 2018, the Federal Circuit affirmed the Patent Trial and Appeal Board’s (the “Board”) Final Written Decision in an inter partes review (IPR) proceeding holding all claims of Anacor Pharmaceuticals, Inc.’s (“Anacor”)...more

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