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Federal Circuit Approves Interim-Director Director Reviews

The Federal Circuit’s decision on May 27, 2022 in Arthrex Inc. v. Smith & Nephew Inc. et al., set forth that Patent Commissioner, Drew Hirshfeld, was within the bounds of the U.S. Supreme Court’s United States v. Arthrex...more

Fintiv Denial Despite Stipulation

On May 9, 2022, the Patent Trial and Appeal Board denied Hillman Group, Inc.’s (“Hillman’s”) three petitions for inter partes review. See The Hillman Group, Inc. v. Hy-Ko Products Co. LLC, IPR2022-00168, -00169, and -00174....more

PTAB News and Notes

Within the past few weeks, the PTAB has issued new guidance addressing a number of important issues including the use of applicant admitted prior art, the Director review process, and changes to PTAB hearings going...more

Legislation: PTAB Reform Act of 2022 (UPDATED)

Since the passage of the America Invents Act in 2012, both petitioners and patent owners have expressed concerns regarding the procedures and practices of the Patent Trial and Appeal Board (PTAB). In an effort to respond to...more

Director to Review Institution of Trial Challenging Patents Found Infringed

U.S. Patent and Trademark Office (“USPTO”) Director Vidal is initiating sua sponte review of the Patent Trial and Appeal Board’s (“PTAB”) decisions to institute inter partes review of two patents owned by VLSI Technology LLC,...more

Legislation: PTAB Reform Act of 2022

On June 16, Senators Leahy, Cornyn, and Tillis introduced the PTAB Reform Act of 2022. The full text of the bill is available...more

Coordinate Arguments To Avoid Procedural Bars

In a recent decision, 25 F.4th 1035 (Fed. Cir. 2022), the Federal Circuit dismissed for lack of jurisdiction an appeal of the PTAB’s decision that estopped a Petitioner from maintaining a third IPR that challenged the same...more

Patent Office Interim Process Aimed To Improve Consistency

On May 26, 2022, the Patent Office issued its “Interim Process for PTAB Decision Circulation And Internal PTAB Review”. The Office issued the Process to explain its new procedures for circulating pre-issuance decisions, which...more

Fintiv Discretionary Denials Remain In Play

F5 Networks, Inc. (“Petitioner”) filed a Petition requesting an IPR.  WSOU Investments, LLC d/b/a/ Brazos Licensing and Development (“Patent Owner”) filed a Preliminary Response. ...more

Third Post-Arthrex Grant of Director Review Issued

On March 3, 2022, Andrew Hirshfeld, the Commissioner for Patents and acting Director of the USPTO, issued the third post-Arthrex grant of Director Review for two separate Final Written Decisions issued by the PTAB based on a...more

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

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

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

CAFC Holds Applicant Admitted Prior Art Cannot be the Basis of an IPR Ground

Section 311(b) limits inter partes review to “ground[s] that could be raised under section 102 or 103 and only on the basis of prior art consisting of patents or printed publications.” 35 U.S.C. § 311(b) (emphasis added). An...more

Section 325(d) – Twelfth Time Not A Charm

This blog has previously discussed PTAB’s exercise of discretion under Section 325(d). Sometimes the PTAB has invoked Section 325(d) to deny institution; sometimes it has declined to apply Section 325(d) and instituted inter...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

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

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