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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

Likelihood of Success on 1 of 46 Claims Deemed Inefficient

The PTAB recently exercised its discretion under 35 U.S.C. § 314 to deny institution of inter partes review for inefficient use of the PTAB’s time and resources notwithstanding that the petitioner met the threshold for...more

Court Opts Not To Stay Without Trial Instituted On All Asserted Patents

Congress implemented the Leahy-Smith America Invents Act (“AIA”) to “establish a more efficient and streamlined patent system that [would] improve patent quality and limit unnecessary and counterproductive litigation costs.” ...more

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

Generative AI-Assisted Patent Inventorship Questions Remain

The Situation: The U.S. Supreme Court recently denied certiorari in Thaler v. Vidal, leaving intact the Federal Circuit's ruling that only human beings, and not artificial intelligence ("AI") systems, can be inventors under...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

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

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

APJ Stock Ownership Insufficient To Vacate

On May 16, 2023, the Federal Circuit denied a petition for a writ of mandamus to direct the Board to vacate an institution decision based on stock ownership of an administrative patent judges (“APJ”) in In re Centripetal...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

Discretionary Denial Despite Stipulation

The Board exercised discretion under § 314 to deny inter partes review in view of co-pending district court litigation.  In the Institution Decision, the Board evaluated the Fintiv factors in light of the USPTO Director’s...more

PTAB Grants Discovery of ITC Documents

In Apple Inc. v. Masimo Corp., the PTAB granted Masimo, the owner of patent 10,687,745 (“the ’745 patent”), their request for production directed to “specific documents identified in regard to [a prior] ITC Investigation,...more

New Case Theories Post-Institution; Better to Ask Permission

Petitioners should be cautious of introducing a new theory in a Petitioner Reply before the PTAB. On February 7, 2023, the Patent Trial and Appeal Board (“PTAB”) entered a final written decision declining to find any claims...more

Director Provides Insight On Interplay Between Written Description And Enablement

USPTO Director Kathi Vidal recently vacated a PTAB decision denying institution of a post-grant review and remanded the case for further proceedings. The petitioner challenged claims 1–27 of the ’274 patent under 35 U.S.C. §...more

How Long Is Too Long To Wait To Settle?

An IPR “shall be terminated with respect to any petitioner upon the joint request of the petitioner and patent owner, unless the Office has decided the merits of the proceeding before the request for termination is filed.” ...more

Federal Circuit Holds Party Can Challenge PTAB Rulemaking

In Apple, Inc. v. Katherine K. Vidal, the Federal Circuit ruled that Apple and the other plaintiffs could continue their suit on a lone surviving challenge to the PTAB Director’s rulemaking procedures regarding institutional...more

Multiple Dependent Claims are Treated as Multiple Claims

On February 24, 2023, Director Kathi Vidal issued a decision under director review granting rehearing and modifying the final written decision for Nested Bean, Inc. v. Big Beings USA Pty. Ltd. Nested Bean, Inc. (“Nested...more

PRECEDENTIAL: Compelling Merits Analysis Only When Other Factors Indicate Denial

In IPR2022-01242, Director Vidal clarified that her prior guidance, which allows the Board to institute inter partes review even if the Fintiv factors favor discretionary denial first requires the Board to find that Fintiv...more

Director Review Orders Additional Discovery On Time Bar-RPI Issue

In Samsung Electronics Co., Ltd. v. Netlist, Inc., the PTAB determined that a time-barred third party was not a real party in interest (“RPI”) and granted institution. IPR2022-00615, Paper 20 (Oct. 19, 2022) at 19...more

Director Vidal Removes OpenSky and PQA from VLSI IPRs, Orders Sanctions

On December 22, 2022, Director Kathi Vidal issued a pair of decisions in the OpenSky v. VLSI saga, dismissing OpenSky Industries LLC (“OpenSky”) and Patent Quality Assurance LCC (“PQA”) from their respective challenges of...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

Director Vacates PTAB Adverse Judgments in Precedential Director Review

Director Vidal’s sua sponte Director Review decision of Apple Inc. v. Zipit Wireless, Inc. (IPR2021-01124, -01125, -01126, -01129) was recently designated as precedential. The decision dealt an immediate setback for Apple...more

Though Not A “Routine Avenue,” Petitioner Permitted To Submit Supplemental Information

The PTAB recently granted Frameless Hardware Company LLC’s (“FHC”) motion to submit supplemental information to its expert’s original declaration in support of institution. FHC had filed two petitions against Patent Owner,...more

PTAB Denies Discovery of Draft Declaration

On November 18, 2022, a panel of three PTAB administrative patent judges denied a Patent Owner’s Request for Additional Discovery in Twitter, Inc. v. Palo Alto Research Center Inc., IPR2021-01398. The PTAB found that...more

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