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Patentability Challenges Not Raised in Prior Interference Foreclosed in Subsequent IPR Petition

A panel at the Patent Trial and Appeal Board recently considered whether a petitioner was estopped from bringing an inter partes review (IPR) based on a judgment in a previous interference proceeding. ...more

Overlooked PTAB Cases: Raising Nonobviousness Evidence

Objective evidence of nonobviousness traces its roots to 19th century case law from the U.S. Supreme Court. The analysis of such secondary considerations as commercial success, failure of others, and long-felt but...more

Patent Owner Granted Leave in IPR to Seek Correction of Claims Held Indefinite in Parallel District Court Litigation

The Patent Trial and Appeal Board recently granted a patent owner’s request to seek a certificate of correction for certain claims of a patent undergoing an inter partes review (“IPR”). In granting the request, the board...more

Agreement Not to Raise Duplicative Arguments in District Court Key to Avoiding Discretionary Denial of IPR Petition

In the last two years, the Patent Trial and Appeal Board has issued two precedential decisions (in NHK and Fintiv) that set forth the board’s test for determining whether to deny an inter partes review (IPR) petition based on...more

PTAB Remains Unwilling to Deny Inter Partes Review Based on a Contractual Forum-Selection Clause

In a recent decision granting institution of an inter partes review (IPR), the Patent Trial and Appeal Board reconfirmed that it will not deny an IPR petition just because the parties previously agreed to resolve their...more

PTAB: Inadvertent Mistake in Analysis of Experimental Data that Substantially Impacts Proceeding Cannot be Corrected

The PTAB recently denied a motion to correct clerical mistakes under 37 C.F.R. § 42.104(c) because the corrections presented substantive new evidence that would have had a substantial impact on the proceedings and prejudiced...more

N.D. Ill.: Neither Statutory Estoppel nor “Misleading” Statements Regarding Its Scope Sufficient to Knock Out Invalidity Defenses

A district court has ruled that the scope of IPR estoppel under 35 U.S.C. § 315(e)(2) did not apply to invalidity grounds that relied on physical products. The court also declined to apply judicial estoppel, notwithstanding...more

PTAB Ruling Highlights a Petitioner’s Burden for Qualifying an Internet Screenshot as a “Printed Publication”

In a recent decision issued in Louisiana-Pacific Corp. v. Huber Engineered Woods LLC, the Patent Trial and Appeal Board addressed the showing that a petitioner for inter partes review must make to demonstrate that an asserted...more

Despite TC Heartland, Forum Selection Clause Controls Venue in Patent Dispute

A district court has ruled that the exclusive statute for determining venue in patent cases, 28 U.S.C. § 1400(b), did not override the parties prior agreement on where suit could be brought. The court also ruled that transfer...more

Strength of Objective Indicia from Prior Litigation Overcomes Strong Obviousness Challenge in IPR

In a recent inter partes review (IPR), a patent owner overcame a facially persuasive obviousness challenge by relying on evidence from an earlier litigation to establish objective indicia of nonobviousness. In RTI...more

No IPR Estoppel Despite Purportedly “Gratuitous” Inclusion of Physical Device in Invalidity Defenses

A district court has ruled that the statutory estoppel arising from an inter partes review (IPR) proceeding does not apply to anticipation and obviousness defenses that rely significantly on a physical device. The court also...more

PTAB: Patent Owner’s Burden Regarding a Showing of Priority Is Strictly Circumscribed by the Extent of Petitioner’s Challenge in...

A petition for inter partes review (IPR) has been denied because the petitioner failed to rebut the patent owner’s claim of priority raised in its preliminary response. In denying institution, the Patent Trial and Appeal...more

District Court: Prosecution History Context Defeats Written Description Requirement

The District Court for the Northern District of West Virginia recently found method of treatment claims directed to treating a specific disease at a specific dose invalid for lack of written description based on the context...more

Can ‘Loophole’ in IPR Statute Lead to Resurgence of DJ Actions?

Declaratory judgment (“DJ”) actions have fallen out of favor in patent cases in recent years. In 2011, DJ complaints made up approximately 11 percent of all patent cases filed that year. Last year, they made up less than 5...more

PTAB’s Claim Construction Not Binding on District Court Despite Affirmance by Federal Circuit of PTAB’s Unpatentability...

An accused infringer in a district court case could not take advantage of a prior claim construction ruling from an inter partes review (IPR) proceeding involving unasserted claims of the same patent. The Patent Trial and...more

PTAB’s Denial of IPR Petition Forecloses Defendant’s Inequitable Conduct Claim in District Court

Relying heavily on the Patent Trial and Appeal Board’s denial of an inter partes review (IPR) petition involving the patent-in-suit, a court in the Eastern District of Virginia recently refused to let the defendant amend its...more

Due to “Apparent Loophole” in Statutory Framework, District Court Permits Invalidity Challenge that Does Not Foreclose Later IPR

When bringing a lawsuit for a declaratory judgment of non-infringement of a patent, careful pleading may allow plaintiffs to avoid the restrictions against later seeking inter partes review (IPR) of that patent, while also...more

Supreme Court Forecloses Judicial Review of PTAB’s Timeliness Determinations

- The Supreme Court ruled 7-2 in Thryv, Inc. v. Click-to-Call Technologies, LP, that the PTAB’s application of the one-year time limit for petitions for inter partes review, set out in 35 U.S.C. § 315(b), is not subject to...more

Priority Dispute Is Not Carte Blanche to Challenge Same Patent with Multiple IPR Petitions

A panel at the Patent Trial and Appeal Board (the “Board”) recently considered whether a dispute over a patent’s priority date justified filing two petitions for inter partes review (IPR) against the same claims. The...more

On Remand, PTAB Reaches Opposite Conclusion and Finds that Patent Owner Successfully Antedated Key Prior Art Reference

In a remanded inter partes review (IPR) proceeding, the Patent Trial and Appeal Board (PTAB) held that Patent Owner Intellectual Ventures II LLC had successfully antedated a prior art reference asserted by Petitioner Motorola...more

Action Seeking Judgment of Compliance with FRAND Obligations Survives Only Insofar as it Relates to U.S. Patent Rights

Optis Wireless Technology, LLC filed a declaratory judgment action in the Eastern District of Texas seeking judgment that it complied with its fair, reasonable and non-discriminatory (FRAND) obligations when it offered a...more

Cancellation of Patent Claims through Reexamination Insufficient to Mount Collateral Attack on Multimillion-Dollar Jury Verdict

Judge Gilstrap in the Eastern District of Texas has denied defendants’ motion to stay the post-trial phase of a patent infringement litigation pending ex parte reexamination where the request for reexamination was filed four...more

District Court Rejects Plaintiff’s Bid to Extend IPR Estoppel to Institution Denials

A federal judge in the Northern District of California recently rejected an argument that would have expanded inter partes review (IPR) estoppel seemingly beyond the plain reading of 35 U.S.C. § 315(e)(2). The plaintiff had...more

PTAB: Correction to Claim of Priority Has No Impact Following a Final Written Decision in an IPR

A panel at the Patent Trial and Appeal Board (PTAB) recently held that a certificate of correction fixing an error in a patent’s claim of priority did not apply retroactively in light of an already issued final written...more

PTAB: Collateral Estoppel Precludes Patent Owner from Advancing Arguments Previously Rejected in IPRs Involving Different but...

A recent ruling from the Patent and Trial Appeal Board (PTAB) highlights the critical role that collateral estoppel (also known as issue preclusion) can play in inter partes review (IPR) proceedings. In a final written...more

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