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District Court Indefiniteness Ruling Leads to Denial

The PTAB exercised its discretion in Samsung Electronics Co., Ltd., v. Acorn Semi, LLC, IPR2020-01182, Paper 17 (Feb. 10, 2021) to deny inter partes review based on a district court finding the challenged claims indefinite....more

Secondary Considerations Unhelpful Second Time Around

On February 26, 2021, the PTAB found in favor of Fox Factory, Inc. (“Fox”) on remand and cancelled the challenged claims of SRAM LLC’s (“SRAM”) U.S. Patent No. 9,182,027 (the ’027 Patent), directed towards anchoring a...more

Jones Day Talks®: Patent Litigation, PTAB, Iancu's Legacy, and Institution Discretion  [Audio]

Partners Matt Johnson and Sarah Geers talk about former USPTO Director Andrei Iancu's impact on the PTAB, and what we might expect from a new director under the Biden Administration. They also comment on why patent litigation...more

PRECEDENTIAL: Trial Court Stay Weighs Strongly Against Fintiv Denial

The USPTO designated Snap, Inc. v. SRK Tech. LLC, IPR2020-00820 (PTAB October 21, 2020) (Paper 15) (“Snap”) as precedential as to § II.A regarding its discretion under 35 U.S.C. § 314(a) to deny institution of inter partes...more

No Rehearing Response During POP Request Pendency

In Sand Revolution II, LLC v. Continental Intermodal Group-Trucking LLC, IPR2019-1393, Paper 19, (PTAB April, 7 2020), the Board denied briefing based on a lack of jurisdiction while the Precedential Opinion Panel request was...more

Boardside Chat: SAS, MTAs, Fintiv, and Indefiniteness

On January 28, 2021, the PTAB held a Boardside Chat webinar at which three PTAB judges discussed four recent developments related to America Invents Act (“AIA”) trials....more

Follow-On Petitions Must Be Justified and Timely

The PTAB recently held that the General Plastic factors weighed in favor of denying a follow-on IPR petition filed after the Patent Owner filed a preliminary response to an earlier petition challenging the same patent (U.S....more

Request for Second Fintiv Preliminary Reply Denied

On January 19, 2021, Petitioner, 10X Genomics, requested via email authorization to file 1) a five page brief addressing the Board’s institution decision in Samsung Electronics Co., Ltd. v. Acorn Semi, LLC, IPR2020-01204,...more

PTAB Greenlights Three Petitions Against One Patent

Although the PTAB had previously stated that it would “rarely” be appropriate for a petitioner to file multiple petitions against the same patent, in Dolby Laboratories, Inc. v. Intertrust Technologies Corp., IPR 2020-01104;...more

PTO Publishes Executive Summary Of AIA-Institution Comments

On January 19th, the PTO published an Executive Summary encapsulating stakeholder feedback received from the October 20, 2020 Request for Comments on institution of America Invents Act (AIA) proceedings. The USPTO received...more

Jones Day’s Fintiv-ITC Developments Tracker

Although first briefly mentioned as a possibility in the August 2018 Trial Practice Guide Update (page 10), outside of one instance (Bio-Rad Labs. v. 10X Genomics, IPR2019-00567; -00568, August 8, 2019), PTAB discretionary...more

Estoppel Estopped for Remanded Claims

In General Access Sols., Ltd. v. Sprint Spectrum, et al., No. 2:20-cv-00007-RWS, ECF No. 128 (E.D. Tex. Dec. 1, 2020), the Eastern District of Texas denied a motion to strike invalidity defenses as barred by IPR estoppel for...more

Staying Still: District Court Extends Stay Pending Appeal

District courts commonly stay patent litigation cases pending inter parties review (IPR) that assesses the validity of the patents-in-suit before the Patent Trial and Appeal Board (PTAB). Such stay may be lifted or extended...more

Multiple-Petition Strategies Fall Into Disfavor

The results of a recent update to the PTAB Multiple Petition Study show Petitioners face an uphill battle when attempting to utilize a multiple petition strategy. These results, discussed during the December 10, 2020...more

Reminder: Estoppel May Not Preclude Prior-Art Systems

The estoppel statute precludes a defendant who has challenged a claim in an IPR reaching final written decision from later challenging that claim on any ground that it raised or reasonably could have raised during the IPR...more

Fintiv Factor Cases Designated Precedential

On December 17th, the PTAB designated two decisions applying the Fintiv factors as precedential.  We will break these cases down in detail in the coming days on the PTAB Litigation Blog. Sotera Wireless, Inc. v. Masimo...more

Fed. Cir. Reaffirms No State Sovereign Immunity in IPRs

In a non-precedential opinion, the Federal Circuit recently reaffirmed that state universities cannot use sovereign immunity to avoid patent challenges at the PTAB stating that, “sovereign immunity does not apply to IPR...more

Book As A Printed Publication? Read Carefully.

Be careful not to confuse reprints with new editions when considering books as printed publications under 35 U.S.C. 102(b). In VidStream LLC v. Twitter, Inc., No. 2019-1734, 2020 WL 6937852 (Nov. 25, 2020), the Federal...more

BREAKING: PTAB Publishes Final Rule Package

On December 8th, the PTAB published a Final Rule, formalizing a number of PTAB practices dictated by case law and described in the current Trial Practice Guide. The one substantive change of note is the removal to deference...more

PTAB Designates RPI, Follow-On Petition Cases Precedential

On December 4th, the PTAB designated the following three cases precedential: RPX Corp. v. Applications in Internet Time, LLC, IPR2015-01750, Paper 128 (Oct. 2, 2020) (precedential) - This decision on remand from the...more

Nexus Required for Objective Indicia

In a recent precedential decision, the PTAB emphasized that objective indicia of nonobviousness must have a nexus to the claimed invention. Lectrosonics, Inc. v. Zaxcom, Inc., No. IPR2018-01129, Paper 33 (P.T.A.B. Jan. 24,...more

Filing Date Motion Granted Due To COVID-19

NeuMoDx Molecular, Inc., (Petitioner) who was otherwise barred from pursuing two IPR proceedings regarding patents owned by HandyLab, Inc. (Patent Owner) under 35 U.S.C. § 315(b)’s one year deadline, filed a Motion to Change...more

PTAB Allows Input on POP Review Requests Using Online Form

The PTAB has added an online form to the USPTO website that allows the submission of an amicus request addressing a pending request for Precedential Opinion Panel (POP) review. This form will enable interested parties to...more

Fed. Circuit Cautions Against Narrow Application of Analogous Art Test

One of the steps in a proper obviousness analysis is to ascertain the scope and content of the prior art and the differences between the prior art and the claims at issue. Graham v. John Deere Co. of Kan. City, 383 U.S. 1,...more

Joinder Bid After Prior Petition Denial Fails

After being sued by Uniloc in April 2018 for infringement of U.S. Patent No. 6,467,088 (“Reconfiguration Manager for Controlling Upgrades of Electronic Devices”), Apple challenged claims 1-21 of that patent at the PTAB in...more

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