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Board Denies Follow-On Petition

In recent decision 3M Company v. Bay Materials, the Board denied 3M Company’s (“Petitioner”) second Petition for inter partes review (“Second Petition”) after exercising its discretion under § 314(a) and finding that each of...more

Customer/Manufacturer Relationship Insufficient To Bar

Recently, the PTAB held that Samsung Electronics Co. Ltd. (“Petitioner”), met its burden in showing that a third party (the “Third Party”) was neither a real party-in-interest (“RPI”) nor in privity with Petitioner....more

Motion to Amend: Much to Admire?

Motions to amend (MTA) are becoming a more frequently used tool for patent owners litigating before the Patent Trial and Appeal Board (PTAB). When a patent is being challenged in an inter partes review (IPR) or post-grant...more

USPTO Provides Insight on AMPRM Proposals

The USPTO issued an advance notice of proposed rules (“ANPRM”) on April 21, 2023 and is requesting comments and feedback from practitioners on proposed, proposed changes at the PTAB. The full ANPRM document is available on...more

Door Closed On Petitioner Who Failed To Prove Analogous Art

A PTAB panel recently denied IPR institution where one of the asserted prior art references was non-analogous and thus the POSITA would not have made the proposed § 103 combination. The Chamberlain Group, LLC v. Overhead...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

Follow On Petition Denied for Implicit “Significant Relationship”

In Ericsson Inc. v. Uniloc 2017, LLC, IPR2019-01550 (PTAB March 17, 2020) (Paper 8), the PTAB denied institution of inter partes review under 35 U.S.C. § 314, exercising its discretion to deny “follow-on petitions”...more

IPR Time Bar Triggered Even If Party Serving Complaint Lacks Standing

The PTAB Precedential Opinion Panel (“POP”) has concluded that the one-year time bar for filing an IPR petition under 35 U.S.C. § 315(b) is triggered by the service of a complaint alleging infringement even if “the serving...more

Timing Is Key in PTAB’s Decision to Review Follow-On Petition by Different Party

Relying on 35 U.S.C. § 314(a), the Patent Trial and Appeal Board has articulated its reluctance to review “follow-on” petitions challenging the validity of patents that have been previously subjected to inter partes review....more

Petitioner Must Explain Differences Among Five Concurrent IPR Petitions

On April 22, 2019, the PTAB issued an order that the Petitioner must explain the differences among its five petitions to institute inter partes review over the same patent, and that the Patent Owner may respond as to whether...more

PTAB Denies Entire IPR Petition as Voluminous and Excessive

In a recent decision, the PTAB exercised its discretion under 35 U.S.C. § 314(a) to deny inter partes review of Perfect Company’s (“Patent Owner”) patent. Adaptics Ltd. v. Perfect Co., IPR2018-01596 (March 6, 2019). A panel...more

Precedential Opinion Provides Factors For Deciding Whether To Allow Live Testimony

Generally, the PTAB does not allow live testimony at oral argument, but recently it designated one of its 2014 decisions as precedential to give guidance as to when the Board will allow live testimony at oral argument. K-40...more

Patent Owner Gets Break On Improper MTA/Reply

On November 30, 2018, the PTAB filed an opinion addressing two procedural issues in Aver Information Inc. v. Pathway Innovations and Technologies, Inc., Case IPR2017-02108, including failure to meet spacing requirements and...more

Speculation Insufficient To Justify Routine Discovery

The PTAB has discretion to permit “routine discovery” under 37 C.F.R. §42.51(b)(1)(iii) when that discovery “is narrowly directed to specific information known to the responding party to be inconsistent with a position...more

PTAB Designates Western Digital as Informative of Motions to Amend

On June 1, 2018, the PTAB announced new guidance on motions to amend in AIA trials. In view of the decision from the United States Court of Appeals for the Federal Circuit in Aqua Products, Inc. v. Matal, 872 F.3d 1290...more

Avoiding Estoppel Is Not Good Cause To Withdraw Grounds After Institution

We recently reported some early observations about possible trends at the PTAB in the wake of the Supreme Court’s decision in SAS Institute Inc. v. Iancu. See Observations: Three Weeks After Supreme Court’s SAS Institute...more

PTAB Permits “Do-Over” of Motion-to-Amend Briefing Following Aqua Products

In its en banc decision in Aqua Products, Inc. v. Matal, the Federal Circuit addressed the question of who bears the burden of proving that claims amended in IPR proceedings are or are not patentable. The decision, issued on...more

Stop What You Are Doing: Collateral Estoppel At The PTAB

On March 13, 2018, in Nestlé USA, Inc. v. Steuben Foods, Inc., 2017-1193 (Fed. Cir. Mar. 13, 2018), the Federal Circuit confirmed that collateral estoppel may preclude the need to revisit an issue that had already been...more

Failure To Maintain Correspondence Address Could Be Detrimental To Your Health

The PTAB rules state that “[t]he petition and supporting evidence must be served on the patent owner at the correspondence address of record for the subject patent.” 37 C.F.R. § 42.105(a). Prompt service is important in IPRs...more

PTAB Designates Two 35 U.S.C. §315(b) Cases Informative

On January 10, 2018, the PTAB designated two decisions weighing on 35 U.S.C. § 315(b) as informative: Luv N’ Care, Ltd. v. McGinley, IPR2017-01216, Paper 13 (P.T.A.B. Sept. 18, 2017) (AIA § 315(b), insufficient funds at...more

PTAB Designates Three Informative Opinions Which Address 35 U.S.C. § 325(d)

On October 24th, the PTAB issued the following notice, designating the following decisions, which address 35 U.S.C. § 325(d), as informative....more

PTAB Decision Provides Guidance On Using Art Previously Considered By The Office

On October 24th, the PTAB designated three decisions related to discretionary petition denials under 35 U.S.C. § 325(d) as informative. Unified Patents, Inc. v. Berman is discussed below. We previously reported on Hospira,...more

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