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Far-Reaching Effect of IPR Estoppel Dooms Invalidity Defense Based on Prior Art Product

Chief Judge Stark granted a patent owner’s motion for summary judgment of inter partes review (IPR) estoppel, holding that obviousness defenses based on a prior art product could not be asserted because a prior art...more

PTAB Casts Doubt on Judicial Estoppel Challenge at Institution Stage of IPR But Does Not Foreclose it for Trial

The Patent Trial and Appeal Board (PTAB) has rejected a patent owner’s argument that judicial estoppel should prevent a petitioner from making obviousness arguments in support of its petition for inter partes review (IPR)....more

Federal Circuit: PTAB Erred In Presuming Nexus Where Commercial Product Was Not Coextensive With Patented Invention

The Federal Circuit vacated and remanded the Patent Trial and Appeal Board’s (PTAB) decisions in two inter partes review (IPR) proceedings, finding that the PTAB applied the wrong standard when it presumed there was a nexus...more

Patent Infringement Suit Against Product Manufacturer Partially Doomed by Prior Suit Against Component Supplier

Chief Judge Saris of the District of Massachusetts has granted-in-part a product manufacturer’s motion seeking summary judgment of claim preclusion based on patentee’s prior assertion of the same patent against a component...more

Prior Art That Was Considered but Not Relied Upon by an Expert is Fair Game for Discovery in IPRs

In inter partes review (IPR) proceedings of patents relating to printer technology, the Patent Trial and Appeal Board (PTAB) granted Patent Owner’s motion to compel testimony over Petitioner’s arguments that the information...more

Request for Letters Rogatory Denied Due to Tardiness and Likely Delay to Trial Date

Chief Judge Gilstrap of the Eastern District of Texas has denied a motion seeking foreign discovery from a third party pursuant to the Hague Convention, holding that the movant waited too long to seek such discovery. The...more

Federal Circuit: Time-Bar Challenge to IPR Doomed by Patent Owner’s Conclusory and Newly Raised Arguments

The Federal Circuit rejected a patent owner’s time-bar challenge to an inter partes review (IPR) proceeding, holding that the patent owner failed to provide sufficient details to establish proper service of a complaint for...more

Invalidity Defenses Will Not Be Stricken at Pleading Stage Despite Defendant’s Earlier PGR Petition

A district court has denied a patent owner’s motion to strike wholesale a defendant’s affirmative defense of invalidity. The key issue in the motion to strike was the application of the estoppel provision of 35 U.S.C. §...more

PTAB Orders Production of Raw Data and Instructions Underlying Test Results

The Patent Trial and Appeal Board (PTAB) recently issued an Order that illustrates the circumstances in which a party may obtain additional discovery in an inter partes review (IPR). In Apple Inc. v. Singapore Asahi Chemical...more

Federal Circuit: Appointment of PTAB Judges Violates the Constitution’s Appointments Clause

In Arthrex, Inc. v. Smith & Nephew, Inc., the Federal Circuit held that appointment of Administrative Patent Judges (APJs) by the Secretary of Commerce violates the Appointments Clause of the U.S. Constitution. The court then...more

Patent Owner Precluded from Asserting in Litigation Claims Obtained Through Ex Parte Reexamination

A district court has denied a request to amend patent infringement contentions to add claims obtained through ex parte reexamination after the case had been substantially narrowed through a parallel inter partes review (IPR)...more

Forum Selection Clause, on Its Own, Does Not Bar PTAB from Instituting IPR Petition

The Patent Trial and Appeal Board has rejected a patent owner’s argument that a forum selection clause found in a Non-Disclosure Agreement (NDA) barred the Board from instituting a petition for inter partes review...more

PTAB Strikes from IPR Record References Introduced After Institution that Purportedly Showed State of the Art

The Patent Trial and Appeal Board has granted in part a Patent Owner’s motion to strike Petitioner’s Reply for improperly raising new arguments and citing new evidence. The Board, however, declined to throw out the entirety...more

Lack of Efficacy Data in Prior Art Dooms PTAB’s Unpatentability Finding for Method of Cancer Treatment Claims

The Federal Circuit recently overturned the Patent Trial and Appeal Board’s (PTAB) determination that claims covering a cancer treatment method were obvious. The patent at issue is directed to a method of treating...more

Misconduct During IPR May Trigger an Award of Attorneys’ Fees in Related District Court Litigation

A magistrate judge determined that a prevailing party in a district court litigation could be entitled to an award of attorneys’ fees based solely on conduct during an inter partes review (IPR) proceeding. In September...more

No Estoppel in District Court on Prior Art that Differs Substantively—and in a Manner Germane to Invalidity—from that Asserted in...

A Central District of California judge has clarified his prior ruling on summary judgment that estoppel under 35 U.S.C. § 315(e)(2) that applies to certain obviousness invalidity grounds raised by Defendants. In the prior...more

Federal Circuit: Statutory Disclaimer Results in No Case or Controversy

The Federal Circuit ruled that statutory disclaimer terminates the case or controversy between the parties in an infringement suit as to those claims, and immediately deprives the district court of the authority to take...more

Withdrawal of Petitioner from IPR Proceeding All But Ensures Success in Contingent Motion to Amend

On remand from the Court of Appeals for the Federal Circuit, the Patent Trial and Appeal Board granted patent owner’s motion to amend on the basis that the totality of the record did not demonstrate by a preponderance of the...more

PTAB: Informal Delivery of Complaint Does Not Start One-Year Clock for Filing IPR

A Patent Trial and Appeal Board (PTAB or Board) panel has determined that emailing a proposed amended complaint is not “service of a complaint” under 35 U.S.C. § 315(b). On January 23, 2018, Aristocrat Technologies, Inc....more

Federal Circuit Refuses to Create Separate Exhaustion and Repair Rules for Design Patents

The Federal Circuit has ruled that neither the exhaustion nor permissible repair doctrines allow manufacture of new replacement components covered by design patents. The Automotive Body Parts Association (ABPA) sued Ford...more

PTAB Finds Good Cause for Staying Ex Parte Reexamination in Light of Parallel IPR

A panel at the Patent Trial and Appeal Board (PTAB) recently considered whether to stay an ex parte reexamination proceeding where the patent was also the subject of a parallel inter partes review (IPR). On September 11...more

PTAB Must Consider Privity and Real Party-in-Interest Relationships Arising After Filing but Before Institution for Time-Bar...

The Federal Circuit vacated a PTAB decision invalidating claims of U.S. Patent No. 6,212,079 (the “’079 Patent”) on the grounds that the inter partes review (IPR) petition was time-barred as a result of a merger between the...more

Nearly Identical Petitions Fail Under Both Post-Grant Review and Inter Partes Review Standards

The Patent Trial and Appeal Board (PTAB) has denied a petitioner’s request for inter partes review (IPR) finding that petitioner failed to demonstrate a reasonable likelihood of prevailing with respect to at least one...more

PTAB: Reexamination Does Not Reset the One-Year Deadline For Filing a Petition for Inter Partes Review

The Patent Trial and Appeal Board has denied a Petitioner’s request for institution of inter partes review (IPR) of claims that were added during ex parte reexamination because it found the IPR petitions were time-barred...more

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