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USPTO Requests Comments Regarding Motion to Amend Pilot

The USPTO continues to seek public feedback on PTAB procedures and potential rule changes. In addition to soliciting comments on the many proposed rule changes announced on April 21, 2023, the USPTO also recently issued a...more

Duty of Candor is Not to be Ignored

In a rare exercise of authority, the PTAB issued sanctions against a Patent Owner for failure to meet its duty of candor and good faith by withholding information relevant to the patentability of challenged and substitute...more

VLSI Claims Deemed Unpatentable

On May 12, 2023, the Intel v. VLSI chronicle continued as the PTAB issued a final written decision holding that all of the challenged claims of VLSI’s U.S. Patent No. 7,725,759 (“the ’759 patent”) were unpatentable as...more

PTAB Panel Excuses Late Filings

On May 10, 2023, a PTAB Panel excused the late filings of the Patent Owner and allowed over thirty exhibits and a Corrected Patent Owner Response (“CPOR”) to be submitted into the record in Samsung Electronics Co., Ltd. v....more

PTAB Issues Back-to-Back Fintiv Denials After Dry Spell

The PTAB recently issued back-to-back Fintiv denials. The first denial issued on May 4, 2023. Read here about Samsung Electronics Co. Ltd. v. California Institute of Tech., No. IPR2023-00130, Paper 10 (P.T.A.B. May 4,...more

Proof of Prior Art Requires Sufficient Corroboration By Credible Evidence

Proof of prior art is an issue that often arises in inter partes and post grant review proceedings before the PTAB. In a recent decision, the Federal Circuit explained the quantum of proof that is required to establish prior...more

Limited Stipulation Results In Fintiv Denial

Patent Owner, IP Bridge, filed a patent infringement suit against Petitioner, Ericsson, for infringement of seven of its patents directed at radio communication between a base station and a mobile station and related...more

OpenSky – Director Finds Abuse Of Process

In OpenSky Industries, LLC v. VLSI Technology LLC, Under Secretary of Commerce for Intellectual Property, Katherine Vidal, issued a precedential decision regarding OpenSky’s violation of the Director’s express order and...more

Patent Owner Ordered To Produce Infringement Contentions

On May 3, 2022, a panel of three PTAB administrative patent judges granted a motion for additional discovery in TCL Industries Holdings Co., Ltd. v. Parkervision, Inc., IPR2021-00985, (PTAB 2022), in which the PTAB deemed the...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

Claim Construction Clash Leads to Invalidity Reprieve

In XR Communications, LLC v. D-Link Systems, Inc. Et. Al., a judge in the Central District of California found that certain asserted claims claiming to wireless communication technology were barred by the doctrine of...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

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

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