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Section 316(a)(11) Time Limits Do Not Apply Beyond First FWD

In Laboratoire Francais du Fractionnement et des Biotechnologies S.A. v. Novo Nordisk Healthcare AG, the Patent Trial and Appeal Board (PTAB) denied the Petitioner’s motion to terminate the inter partes review (IPR) and to...more

Healthy Overlap Between PTAB And Trial Court Favors Denial

The PTAB recently denied institution of inter partes review (IPR) for claims 1 and 46 of U.S. 7,464,040 in eClinicalWorks, LLC et al. v. Decapolis Systems, LLC, IPR2022-0229, Paper 10 (PTAB April 13, 2022). The denial was...more

Reexam References Count In Section 325(d) Analysis

The Board denied post grant review in Palo Alto Networks, Inc. v. Centripetal Networks, Inc. under 35 U.S.C. § 325(d) after applying the Advanced Bionics framework as informed by the factors outlined in Becton. IPR2021-01520...more

PTAB Denies Joinder Motion Filed More One Month After PGR Institution

Typically, a Motion for Joinder to an earlier post-grant review (“PGR”) must be filed within one month of the institution of the earlier PGR. 37 C.F.R. § 42.222(b).While the Patent Trial and Appeal Board (“PTAB”) does have...more

Petition Survives Word Count Complaint And Request for Withdrawal

The PTAB recently denied a motion to dismiss a Revised Petition and terminate an inter partes review (IPR) proceeding despite Petitioner’s alleged withdrawal of the Original Petition and failure to comply with the word limit...more

Joinder Denied For Petitioner Whose Invalidity Case Was Dismissed With Prejudice

In the PTAB’s recent decision in Code 200 v. Bright Data Ltd., IPR2021-01503, Paper No. 13 (PTAB Mar. 14, 2022), the PTAB expounded upon the circumstances in which joinder of a “me-too” case under § 315(b) was not...more

PTAB Does Not Provide a Supplemental Discovery Venue

Following the grant of institution of a recent IPR petition in the matter of Satco Products, Inc. v. The Regents of the University of California, IPR2021-00662, Paper 26 (PTAB Feb. 11, 2022) concerning U.S. Patent No....more

RPI: Not Quite a Jurisdictional Requirement

Recently, the Patent Trial and Appeals Board (PTAB) declined to terminate an inter partes review (IPR) proceeding despite the Petitioner’s alleged failure to identify all the real parties-in-interest (RPIs)....more

PTAB Statistics Through Four Months of FY2022

The institution rate for post-grant petitions in FY 2022 through the end of January 2022 (Oct. 1, 2021 through January 31, 2022) stands at 63% (279 instituted, 164 denied) compared to 59% in the previous fiscal year....more

Don’t Save The Best: Federal Circuit Confirms Broad IPR Estoppel

The patent fight between Caltech and Broadcom/Apple made waves this month when the Federal Circuit vacated the $1.1 billion infringement award that Caltech had won in district court....more

PTAB Statistics Through Two Months of FY2022

The institution rate for post-grant petitions in FY 2022 through the end of November 2021 (Oct. 1, 2021 through Nov. 30, 2021) stands at 66% (138 instituted, 71 denied) compared to 59% in the previous fiscal year....more

Board Requires Settlement Agreement to Dismiss Pre-Institution Proceeding

Biofrontera AG (“Petitioner”) filed an unopposed motion to dismiss the petition during the preliminary phase of the proceedings.  Here, DUSA Pharmaceuticals, Inc. (“Patent Owner”) had not yet filed a Preliminary Response, and...more

Use Caution When Mapping Multi-Forum Patentability Attack

A recent PTAB decision in Sattler Tech Corp. v. Lyu represents an important reminder to carefully review the procedural and substantive requirements for filing a petition for an AIA trial, especially when dealing with...more

Printed Publication Proof – Cross T’s And Dot I’s

On November 30, the PTAB entered its final written decision in Unified Patents, LLC v. 2BCom, LLC on the patentability of the claims of U.S. Patent No. 7,127,210 (the ‘210 patent).  ...more

Prior Art Wanted—Cash Reward

Recently, Cloudflare Inc. succeeded in convincing the PTAB to institute in IPR2021-00969 against a Sable Network, Inc.’s patent directed toward data flow. While the institution itself is not out of the ordinary—the...more

Final FY2021 PTAB Statistics Posted

The statistics from the PTAB for FY2021 are in, and the total PTAB petitions filed in FY2021 are down a bit from the previous year.  A total of 1,401 petitions were filed—IPR (1308) and PGR (93)—compared to 1513 in FY2020,...more

Limited Experiment Protocol Discovery Granted

In an inter partes review (IPR), the scope of discovery is expressly stated in the C.F.R. and additional discovery must either be agreed upon by the parties or granted by the Board when it “is necessary in the interest of...more

PTAB Lifts Arthrex Remand Stay

On October 26, 2021, Chief Administrative Patent Judge (“APJ”) Boalick lifted a May 1, 2020 stay issued by the PTAB pending the Supreme Court’s consideration of Arthrex in which 103 cases were placed in “administrative...more

Introducing Evidence Before Authorization May Result in Expungement

Introducing evidence in a motion to file a reply to a patent owner’s preliminary response without the PTAB’s authorization may result in denial and expungement. A recent motion met such a fate in Ice Castles, LLC v....more

Late Request Results In Denial Of Motion To Strike Authorization

Patent Owner (Provisur Technologies) requested authorization to file a motion to strike portions of Petitioner’s (Weber, Inc.) Reply and certain evidence submitted therewith, which Petitioner opposed.  Patent Owner argued...more

Kathi Vidal Nominated for USPTO Director

On October 26, 2021, President Biden nominated Kathi Vidal – the managing partner of Winston and Strawn’s Silicon Valley office – as Director of the United States Patent and Trademark Office (USPTO).  ...more

PTAB Strikes Patent Owner Sur-Reply Exhibits

Rule 42.23(b) is clear, “A sur-reply may only respond to arguments raised in the corresponding reply and may not be accompanied by new evidence other than deposition transcripts of the cross-examination of any reply...more

Leahy-Corbin Proposals for “Restoring the America Invents Act”

We recently reported on bipartisan legislation introduced by Senators Patrick Leahy (D) and John Cornyn (R) to significantly revamp certain features of the America Invents Act (AIA), ten years after its debut.  This proposed...more

PTAB Statistics Through Eleven Months of FY2021

The institution rate for post-grant petitions in FY 2021 through the end of August 2021 (Oct. 1, 2020 through Aug. 31, 2021) stands at 58% (658 instituted, 471 denied) compared to 56% in the previous fiscal year.  The Patent...more

Secrets on the Road: Protecting Trade Secrets of Highly Automated Vehicles Against Public Disclosure

Trade Secrets in the HAV Industry Trade secrets are invaluable in the HAV industry as its growth accelerates in the fast lane. HAV players defend their technology aggressively against competitors and departing employees who...more

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