News & Analysis as of

Real Party in Interest § 315(b)

McDermott Will & Emery

No Need for Unnecessary RPI Determinations

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The US Patent & Trademark Office Director partially vacated the Patent Trial & Appeal Board’s real-party-in-interest (RPI) determination because that determination was not necessary to resolve the underlying proceeding....more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Federal Circuit Appeals from the PTAB and ITC: Summaries of Key 2022 Decisions: Atlanta Gas Light Co. v. Bennett Regulator Guards,...

Atlanta Gas petitioned for inter partes review of Bennett’s ’029 patent. The Board initially rejected Bennett’s argument that Atlanta Gas was time barred from petitioning for inter partes review under 35 U.S.C. § 315(b) and...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Federal Circuit Appeals from the PTAB and ITC: Summaries of Key 2022 Decisions

As part of the recovery from the global COVID-19 pandemic, the U.S. Court of Appeals for the Federal Circuit took steps to return to normal operations. It began requiring live oral arguments in August 2022 and, by November,...more

Snell & Wilmer

IPRs Terminated by PTAB After Petitioner Failed to Name Client as RPI

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In RPX Corp. v. Applications in Internet Time LLC, the Patent Trial and Appeal Board (“PTAB”) held in a precedential opinion that three inter partes reviews (“IPRs”) were time-barred under 35 U.S.C. § 315(b) because the...more

Jones Day

Federal Circuit’s Applications in Internet Time Decision Applied

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Throughout the Patent Trial and Appeal Board’s (“PTAB”) history, patent owners have tried to leverage a petitioner’s alleged failure to name all real parties-in-interest (“RPIs”) as a way to achieve denial of an inter partes...more

Jones Day

Section 315(a) Calls At Institution Cannot Be Reviewed

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Recently, we reported about the Supreme Court’s decision holding that the AIA’s “no appeal” provision in 35 U.S.C. § 314(d) means that the PTAB’s decision not to institute IPR because a petition is time barred under 35 U.S.C....more

Knobbe Martens

IPR Real-Parties-In-Interest Determination Is Final and Non-Appealable

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ESIP SERIES 2, LLC V. PUZHEN LIFE USA, LLC - Before Reyna, Lourie, and Hughes. Appeal from the Patent Trial and Appeal Board. Summary: The PTAB’s determination that an IPR petition identifies all real parties in...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

PTAB Strategies and Insights - March 2020: 315(b) Jurisdictional Issues Can Still Be Waived if not Raised at the Board

In Acoustic Technology v. Itron Networked Solutions, the Federal Circuit was faced with a situation in which the Petitioner’s real party-in-interest/privy changed after institution, although the change was in the works before...more

Jones Day

Don’t Wait Too Late to Assert the § 315(b) Time-Bar

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In two related decisions, the Federal Circuit held that the Patent Owner, Acoustic Technology, Inc. (“Acoustic”) waived its time-bar challenges under 35 U.S.C. § 315(b) (“Section 315(b)”) by failing to assert them in the IPR...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Federal Circuit Appeals From The PTAB: Summaries of Key 2019 Decisions: Power Integrations, Inc. v. Semiconductor Components...

Semiconductor Components, doing business as ON Semiconductor, petitioned for inter partes review (IPR) of several claims of Power Integration’s U.S. Patent No. 6,212,079. The Patent Trial and Appeal Board (PTAB) instituted...more

Knobbe Martens

Time-bar Challenges to IPR under Section 315(b) Can Be Waived

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Time-bar Challenges to IPR under Section 315(b) Can Be Waived - ACOUSTIC TECHNOLOGY INC. v. ITRON NETWORKED SOLUTIONS INC (NOS. 2019-1059 & 2019-1060) - ACOUSTIC TECHNOLOGY INC. v. ITRON NETWORKED SOLUTIONS INC (NO....more

Jones Day

PTAB Declines Institution After Discovery of Unnamed Real Party in Interest

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To institute an inter partes review (IPR), the petition requesting the proceeding must be filed within one year of the petitioner or real party in interest (RPI) receiving a complaint alleging patent infringement. 35 U.S.C. §...more

Jones Day

PTAB Precedential Decision Recap

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The PTAB has been very active in designating decisions precedential and informative in 2019. Here’s a recap of designations so far...more

Mintz - Intellectual Property Viewpoints

Prior Civil Action Bars IPR - A precedential decision

On August 29, 2019, the Patent Trial and Appeal Board (PTAB) designated as precedential its January 31, 2019 decision in Cisco Systems, Inc. v. Chrimar Systems, Inc. In Cisco, the PTAB held that 35 U.S.C. § 315(a)(1) bars...more

Jones Day

PTAB Abused Discretion in Denying Request to File Motion for Additional Discovery

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In a recent appeal of two inter partes review (“IPR”) decisions from the Patent Trial and Appeal Board (“Board”), The Court of Appeals for the Federal Circuit (“CAFC”) held that the Board abused its discretion in denying...more

McDermott Will & Emery

Late Identification of Real-Party-in-Interest Permitted Even Where It Would Otherwise Create Time-Bar

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Addressing whether the Patent Trial and Appeal Board (PTAB) is permitted to excuse an inter partes review (IPR) petitioner’s late identification of additional real-parties-in-interest (RPIs), the US Court of Appeals for the...more

McDermott Will & Emery

Pre-Institution Merger Creates Time Bar Under § 315(b)

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Addressing for the first time whether real-parties-in-interest (RPIs) are evaluated at the time a petition is filed or at the time of institution for purposes of § 315(b), the US Court of Appeals for the Federal Circuit held...more

Faegre Drinker Biddle & Reath LLP

Reading the Supreme Court Tea Leaves in Dex Media Inc. v. Click-to-Call Technologies, LP

On June 24, 2019, the U.S. Supreme Court granted the petition for certiorari in Dex Media Inc. v. Click-to-Call Technologies, LP. Next term, the Court will determine whether 35 U.S.C. § 314(d) permits appeal of the U.S....more

Akin Gump Strauss Hauer & Feld LLP

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

Foley & Lardner LLP

Buyer Beware: Post-Facto Mergers a New Potential IPR Killer

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Overturning prior PTAB precedent, the Federal Circuit has now held that post-facto business mergers that create a new real-party-in-interest (“RPI”) trigger the one-year bar date for filing IPR petitions on patents asserted...more

Jones Day

Post-Filing, Pre-Institution Merger Time-Bars Inter Partes Review

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In Power Integrations v. Semiconductor Components, the Federal Circuit ruled that privy and real-party-in-interest (RPI) relationships arising after a petition is filed but before institution may bar institution under section...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

PTAB Strategies and Insights - June 2019

The PTAB Strategies and Insights newsletter provides timely updates and insights into how best to handle proceedings at the USPTO. It is designed to increase return on investment for all stakeholders looking at the entire...more

Knobbe Martens

One-Year Clock for Filing IPR Petition Applies to Litigants and Parties That Become Privies of the Litigant Prior to Institution

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POWER INTEGRATIONS, INC v. SEMICONDUCTOR COMPONENTS - Before Prost, Reyna, and Stoll. Appeal from the Patent Trial and Appeal Board. Summary: An IPR is time-barred under 35 U.S.C. § 315(b) if, at the time of...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Federal Circuit clarifies that a post-filing change in RPI status can trigger the § 315(b) time-bar

Federal Circuit clarifies that a post-filing change in RPI status can trigger the § 315(b) time-bar and that there are exceptions to issue preclusion in IPR appeals - On June 13, 2019, the Court of Appeals for the Federal...more

Jones Day

PTAB Designates § 315(b) Time Bar Order Precedential

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In an order designated precedential, the PTAB terminated an instituted IPR proceeding after the petitioner failed to establish that no real parties in interest (“RPI”) or privies had been served with a complaint more than one...more

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