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PTAB Allows Three Concurrent IPR Petitions for Unusual Patent Claims

Recently, the Patent Trial and Appeal Board (“the Board”) was persuaded to consider the merits of three out of seven concurrent petitions for an inter partes review of a single patent due to the patent’s complicated claiming...more

PTAB Finds Petition Time Barred

In 2985 LLC d/b/a Mountain Voyage Company, LLC v. The Ridge Wallet LLC, a Patent Trial and Appeal Board (“PTAB”) panel denied inter partes review (“IPR”) institution where the petition was time barred under 35 U.S.C. § ...more

Federal Circuit Reverses District Court’s Application Of Collateral Estoppel

Kroy IP Holdings, LLC sued Groupon, Inc., alleging infringement of 13 claims of U.S. Patent No. 6,061,660 (“’660 patent’), which relates to incentive programs over computer networks. Those claims were invalidated via...more

Provisionals’ Disclosures Must Fully Support an Issued Claim for Pre-AIA Priority

The PTAB recently provided a pre-AIA priority analysis for reference patents in Roku, Inc. v. Anonymous Media Research Holdings, LLC, No. IPR2024-01057, Paper 10 (P.T.A.B. Feb. 10, 2025). This decision highlights the...more

PTAB Pendulum Swings in Favor of Discretionary Denial

Recent developments at the USPTO suggest a significant shift in favor of the PTAB exercising discretionary denial and uncertainty on behalf of parties to PTAB proceedings.  ...more

Motivation to Modify Prior Art Need Not Be the Same as Challenged Patent

Honeywell filed a petition for inter partes review of 3G Licensing’s U.S. Patent No. 7,319,718, which claims a coding scheme for transmitting information in 3G mobile communication systems. The PTAB found none of the...more

PTAB Retains Jurisdiction Of Expired Patents

The Federal Circuit rejected a recent argument that the PTAB does not have inter partes review (IPR) jurisdiction over expired patents. Because even expired patents involve the grant of public rights, the court explained that...more

PTAB Rescinds Discretionary Denial Memorandum

On Friday, the USPTO rescinded its June 21, 2022, guidance memorandum entitled “Interim Procedure for Discretionary Denials in AIA Post-Grant Proceedings with Parallel District Court Litigation.”  That memorandum discussed...more

Two Separate Analyses: Nonobviousness vs Enablement

Recently, a Director Review was granted where Director Vidal vacated the Patent Trial and Appeals Board’s (“PTAB”) Final Written Decision and remanded back to the PTAB for further consideration of enablement.  Duration Media...more

Federal Circuit Remands Based On Inadequate Explanation

Palo Alto Networks (PAN) filed a petition for inter partes review of Centripetal Networks’ patent—U.S. Patent No. 10,530,903—which is directed to a computing system for correlating packets in communication networks with a...more

No Need to Show Reasonable Expectation of Success Regarding Inherent Property

The Federal Circuit affirmed six PTAB decisions that held unpatentable as obvious 79 claims of three Cytiva Bioprocess (“Cytiva”) challenged patents and reversed the PTAB decision upholding four claims....more

Similar Claims in Prior IPR Petition Leads to Denial

The PTAB recently denied institution of inter partes review of a patent directed to deep packet inspection in software defined networks in Juniper Networks, Inc. v. Orckit Corporation, IPR2024-00895. Applying the General...more

When Is a Published Patent Application Prior Art in an IPR?

On appeal from an inter partes review (“IPR”), the Federal Circuit held that, under pre-America Invents Act (“pre-AIA”) law, a published patent application is prior art as of its filing date as opposed to its later date of...more

Two Many IPRs: Different References Insufficient for Parallel IPRs

The Patent Trial and Appeal Board (“PTAB”) recently denied institution in an inter partes review (“IPR”) where Petitioner later filed a parallel petition against the same claims of the same patent.   Shenzhen Root Tech. Co.,...more

Thickness Arguments Cross the Line for Federal Circuit

When issued patent drawings are not explicitly made to scale, the Federal Circuit recently confirmed that arguments relying solely or predominately on the features of those drawings, such as line thickness, are “unavailing.” ...more

PTAB Fee Increases in 2025

Petitioners may soon need to check their account balances, as the United States Patent and Trademark Office (“USPTO”) is raising patent fees across the board, effective January 19, 2025. 89 Fed. Reg. 91898....more

New Declarations with a Sur-reply Require Extraordinary Circumstances

In a 2-1 decision, the Patent Trial and Appeal Board (“PTAB”) denied a patent owner’s motion to file two new declarations in connection with its sur-reply, holding that the patent owner failed to prove the extraordinary...more

PTAB Reiterates Strict Evidentiary Standard for Printed Publications

The PTAB denied institution of inter partes review (IPR) for a patent directed to geothermal technology. Fervo Energy Co. v. Ormat Techs. Inc., IPR2014-00665, Paper 18 (PTAB Sept. 18, 2024). The claimed invention related to...more

PREVAIL Act Passes Committee

The Promoting and Respecting Economically Vital American Innovation Leadership (“PREVAIL”) Act has moved to the Senate for a full vote after passing the Senate Judiciary Committee vote 11-10 on November 21, 2024. In...more

“First Available” Date Alone Is Insufficient Evidence of Disclosure

The Patent Trial and Appeal Board (“PTAB”) denied institution in an inter partes review (“IPR”), finding that an online store’s assertion regarding when a product was “first available” is by itself insufficient evidence of...more

Expert Testimony That Does Not Disclose Underlying Facts Or Data Entitled To Little Weight

“Expert testimony that does not disclose the underlying facts or data on which the opinion is based is entitled to little or no weight.” 37 C.F.R. § 42.65(a). With that principle in mind, the PTAB recently denied institution...more

The “Best Way” to Avoid Adverse Judgment

The PTAB recently denied Bestway (USA), Inc.’s (“Petitioner”) request for PGR of U.S. Pat. No. 11,959,512 B2 (“the ’512 patent”) but declined to enter adverse judgment against Intex Marketing, Ltd. (“Patent Owner”) for...more

District Court Not Persuaded System Prior Art Evades IPR Estoppel

On October 25, 2024, the United States District Court for the Eastern District of Pennsylvania ordered Comcast Corporation (“Comcast”) to identify the date on which it learned of each patent, patent application, and printed...more

Petitioner Mistakenly Ignores Not-So-Optional Claim Limitation

The PTAB recently excluded a portion of Duration Media LLC’s (Petitioner) reply declaration for containing improper new evidence in an inter partes review petition filed against Rich Media Club LLC (Patent Owner) challenging...more

Don’t Wait To Seek Discovery Or It May Be Too Late

“The statutory provisions for inter partes reviews, post-grant reviews, and covered-business method patent reviews caution against overly broad discovery and provide the same considerations, including efficient administration...more

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