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Error In Declaration Insufficient To Sink IPR

In a precedential opinion, the Court of Appeals for the Federal Circuit vacated a final written decision in which the Patent Trial and Appeal Board (“PTAB”) found that Apple had failed to meet its burden of showing...more

Salesforce’s Reexams Estopped by RPX IPRs

In decisions rare of their kind, the U.S. Patent and Trademark Office (“USPTO”) terminated two ex parte reexaminations in view of inter partes review (“IPR”) proceedings initiated by a different party. The decisions represent...more

Director Determines Petitioner Not Expected to Anticipate § 325(d) Argument

Director Vidal recently vacated a decision denying institution of an inter partes review (“IPR”) to allow Google, the Petitioner, to brief whether discretionary denial was warranted under Section 325(d) in view of a European...more

FWDs Issue in the Nick of Time to Suspend ITC Orders

After finding that Apple infringed certain AliveCor patents related to wearable devices capable of monitoring a user’s cardiac activity, the International Trade Commission (“ITC”) entered a limited exclusion order and a cease...more

Reliance on Machine Translations Warrants Denial of IPR Petitions

By Marc Blackman – An IPR petitioner that relies on foreign language prior art must submit an English language translation of the reference along with an affidavit attesting to the accuracy of the translation.  In a recent...more

Despite Uncertain Trial Date, PTAB Denies Institution

Applying the PTAB’s precedential NHK decision, the PTAB exercised its discretion to deny institution of three timely filed IPR petitions due to the advanced stage of a related district court action. Intel Corporation v. VLSI...more

PTAB Focuses on IPR Control to Determine RPI

In three related final written decisions, the PTAB ruled that Bayer Healthcare (“Bayer”) was not a real party in interest (“RPI”) to IPR petitions filed by NOF Corporation, even though Bayer had a business relationship with...more

Decision to Deny Institution not Reviewable Despite Prior PTAB Trial

In a split decision, the Federal Circuit dismissed three consolidated appeals holding that the PTAB’s decisions to deny institution were not appealable even though the PTAB previously had instituted the IPRs and proceeded...more

PTAB Orders Petitioner’s Expert to Produce Discovery

The PTAB recently granted a Patent Owner’s motion to take additional discovery of Petitioner’s expert. In particular, the PTAB ordered Petitioner’s expert to produce documents that identify materials he reviewed in preparing...more

Forum Selection Clause May Preclude PTAB Proceedings

The Federal Circuit recently affirmed a preliminary injunction barring PTAB proceedings in view of a forum selection clause. Dodocase VR, Inc. v. MerchSource, LLC, 2018-1724 (Fed. Cir. Apr. 18, 2019). Dodocase, the owner...more

Rule 36 Judgment May Support Finding of Collateral Estoppel

The Federal Circuit recently affirmed final written decisions in two inter partes reviews by holding that the patent owner was collaterally estopped from relitigating the threshold issue of whether a prior art reference was a...more

Seeking District Court Assistance For An IPR Proceeding

Discovery is limited in inter partes review proceedings. As we previously discussed, discovery is available only “in the interest of justice,” and requests for discovery frequently are denied. Yet, a party may be aware of...more

When Is A Timely IPR Petition Not Timely Enough?

A petition for inter partes review is timely if it is filed within one year of service of a complaint alleging infringement of the challenged patent on the petitioner, real party in interest, or privy of the petitioner. 35...more

Institution Denied: Pending Federal Circuit Appeal Warrants Denial of IPR

The PTAB recently exercised its discretion to deny institution of an IPR proceeding because a potentially dispositive claim construction issue was pending before the Federal Circuit. Comtech Mobile Datacom Corp v. Vehicle IP,...more

Patent Transfer to Native American Tribe Does Not Immunize Patents from Inter Partes Review

This ruling may have eliminated the practice of transferring patents to Native American tribes for immunization from IPR proceedings. The Federal Circuit, in a matter of first impression, has ruled that tribal sovereign...more

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