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Director Vacates Decision Based on Improper Claim Construction

The PTAB denied institution of inter partes review reasoning that Petitioner did not demonstrate a reasonable likelihood that Petitioner would prevail in establishing the unpatentability of any of the challenged claims. The...more

Institution Denied For Lack of Sufficient Structure

The Board declined to institute inter partes review because Petitioner failed to identify adequate corresponding structure in the challenged patent that performed the function of claim limitation that was to be construed...more

Statutory Disclaimer After Petition Bars Institution

In IPR2023-01058, the PTAB declined to institute IPR, finding that Patent Owner had disclaimed all challenged claims under 35 U.S.C. § 243(a), in compliance with 37 C.F.R. § 1.321(a), such that there was no basis on which to...more

Patent Owner Unable to Change Inventorship During Remand

At the Inter Partes review trial, Patent Owner attempted to swear behind Petitioner’s primary prior art reference by showing that the inventors of the asserted patents had conceived of the invention before the priority date...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

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

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

Panel Denies Joinder Based On Intervening Institution

The PTAB denied a request for institution and joinder because the petitioner was the petitioner in one other instituted IPR directed to the same patent, and the petitioner did not explain adequately to the PTAB why another...more

Petitioner Estopped On “Uninstituted” Claim

Click-to-Call (Plaintiff/Patent Owner) filed an infringement suit against Ingenio (Defendant/Petitioner) and others. Defendant filed an IPR challenging the asserted claims. In the IPR petition, Petitioner asserted multiple...more

Fintiv Discretionary Denials Remain In Play

F5 Networks, Inc. (“Petitioner”) filed a Petition requesting an IPR.  WSOU Investments, LLC d/b/a/ Brazos Licensing and Development (“Patent Owner”) filed a Preliminary Response. ...more

PGR Estoppel Continues to be Broad and Onerous

An ITC Administrative Law Judge (ALJ) recently issued an initial determination holding that PGR estoppel prevented GMG Products LLC (Respondent) from raising two prior-art products in the ITC....more

Board Requires Settlement Agreement to Dismiss Pre-Institution Proceeding

Biofrontera AG (“Petitioner”) filed an unopposed motion to dismiss the petition during the preliminary phase of the proceedings.  Here, DUSA Pharmaceuticals, Inc. (“Patent Owner”) had not yet filed a Preliminary Response, and...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

PGR Ineligible – Petitioner Failed to Show Post-AIA Priority

Ocado Group (“Petitioner”) filed a petition requesting a post-grant review of a claim from U.S. Patent No. 10,696,478 (’478 Patent) owned by AutoStore Technology (“Patent Owner”).  The Board concluded that the Petitioner did...more

PTAB Declines to Exercise Discretion Post-Markman

Petitioner (Apple, Inc.) filed a petition to institute inter partes on a patent owned by Koss Corporation (Patent Owner). The PTAB considered six factors from Fintiv to assess whether to exercise authority to deny...more

Two’s a Crowd: Prior Art in Design Patent Claim Construction

On April 15, 2021, the PTAB issued a Final Written Decision in the LKQ Corp. case finding a design patent claiming a vehicle fender panel unpatentable as obvious. IPR2020-00064, Paper No. 39 (Apr. 15, 2021). The obviousness...more

FedEx Delivery Sufficiently Akin to Priority Mail Express for Petition Service

A PTAB panel found FedEx sufficiently akin to Priority Mail Express to meet the petition service rule, and to the extent necessary further waived the regulatory requirements related to the timing of Petitioner’s (TIZ Inc....more

Fed. Cir. Reaffirms No State Sovereign Immunity in IPRs

In a non-precedential opinion, the Federal Circuit recently reaffirmed that state universities cannot use sovereign immunity to avoid patent challenges at the PTAB stating that, “sovereign immunity does not apply to IPR...more

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