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91%: That is the Rate at Which the PTAB Affirms Examiner Section 101 Rejections

Over the last two years, we have studied the examiner affirmance rates of the Patent Trial and Appeal Board (PTAB) for § 101 rejections.  The PTAB is the administrative court of the U.S. Patent and Trademark Office (USPTO)...more

An Empirical Study of Low Allowance Rate Examiners

Any patent attorney who has been in the business for more than a few years understands from experience that some USPTO examiners are tougher than others.  This should not be surprising, as each examiner is an individual who...more

AI News Roundup – Director Vidal Memo, UK AI Safety Institute, ancient Roman scrolls deciphered and more

There’s a lot happening in the world of AI. To help you stay on top of the latest news, we have compiled a roundup of the developments we are following. Kathi Vidal, Under Secretary of Commerce for Intellectual Property and...more

Axonics, Inc., v. Medtronic, Inc. (Fed. Cir. 2023)

Establishing a prima facie case of obviousness based on a multiple prior art references generally requires that the references teach or suggest all claim elements and that one of ordinary skill in the art would be motivated...more

You Are Going to Hear A Lot More FUD about Patent Law, So Here Are Some Facts

They may have known that it was coming.  Over the last several weeks, lobbying organizations and high-tech blogs have been slowly introducing the same old false, misleading, and deceptive arguments against patent law.  These...more

Senators Tillis and Coons Once More Attempt to Fix Patent Eligibility

Patent eligibility is broken. The only semi-cogent arguments that I have ever heard in support of the status quo is that the U.S. Patent and Trademark Office issues too many broad, vague patents, and that 35 U.S.C. § 101...more

[Webinar] The Weird And Evolving Landscape Of Software And Business Method Patent Eligibility - March 9th, 10:00 am - 11:15 am CST

The interpretation of 35 U.S.C. 101 has been in flux for over a decade. Please join MBHB Partner Michael Borella, Ph.D., as he discusses its latest iteration, how patent eligibility is currently viewed by the USPTO and...more

PTAB Remains Hostile to Section 101 Appeals

There is ample evidence that patent examiner allowance rates vary dramatically from examiner to examiner and art unit to art unit.[1]  This has resulted in the general understanding that there are "easy" examiners and "tough"...more

The Mental Process Exception to Patent Eligibility is Remarkably Brainless

In Liu Cixin's novel The Three Body Problem, the characters create a "computer" from human labor.  Millions of people serve as "bits" and hold up flags to indicate whether they represent 0s or 1s.  These individuals are given...more

In re Smith (Fed. Cir. 2022)

In a ruling that should surprise absolutely nobody, the Federal Circuit rapidly scrapped an appeal of a PTAB decision that affirmed a 35 U.S.C. § 101 rejection of a business method claim.  This is the latest in a series of...more

Think Twice About Appealing a § 101 Rejection to the PTAB

The U.S. Patent and Trademark Office (USPTO) established its Patent Trial and Appeal Board (PTAB) in September 2012.  As mandated by the America Invents Act, the PTAB conducts administrative trials, such as inter partes...more

ClearOne, Inc. v. Shure Acquisition Holdings, Inc. (Fed. Cir. 2022)

Self-similarity is a characteristic found in many physical, natural, and human-made systems.  In short, it describes a class of structures or behaviors that are at least partially-invariant to time or scale.  Thus, these...more

LG Electronics v. Immervision, Inc. (Fed. Cir. 2022)

Can a prior art reference with an error be considered to be a disclosure of the erroneous teaching?  A Federal Circuit panel split over this issue, with their disagreement largely based on how apparent the error would be to...more

A Few Things that USPTO Could Do to Simplify Patent Prosecution

The U.S. Patent and Trademark Office handles hundreds of thousands of patent applications per year, as well as various types of administrative patent proceedings.  While the USPTO has made incremental improvements in its...more

The Federal Circuit Addresses Commercial Success

In academic settings, objective indicia of non-obviousness are sometimes presented as a common way of rebutting contentions that a claimed invention is obvious.  These indicia, set forth in Graham v. John Deere Co. and...more

MyMail, Ltd. v. ooVoo, LLC (Fed. Cir. 2021)

Two years ago, MyMail and ooVoo went to the mat in the Federal Circuit over claims that the District Court for the Northern District of California found ineligible under 35 U.S.C. § 101.  Patent holder MyMail was able to...more

Raytheon Technologies Corp. v. General Electric Co. (Fed. Cir. 2021)

The legal concept of obviousness is tricky.  A claimed invention is found obvious if the prior art teaches or suggests all claim limitations and one of ordinary skill in the art would have been motivated to combine the...more

Gree, Inc. v. Supercell Oy (Fed. Cir. 2020)

One would think that inventions relating to computer game software would easily meet the requirements for patent eligibility, as these inventions fundamentally involve technological processes and require computer...more

Stupid § 101 Tricks

If we have learned anything from the last six-and-a-half years of patent eligibility jurisprudence, it is that nobody knows what's going on. Subject matter eligibility is a fundamental requirement for an invention to be...more

USPTO Assesses the Impact of Patent Eligibility's Changing Landscape

In a post-truth world, it is more tempting than ever to evaluate data based on gut instinct, intuition, and anecdotal evidence.  It is thus refreshing when results of a robust statistical analysis are published, even if the...more

What is an Abstract Idea, Anyway?

In 2014's Alice Corp. v. CLS Bank Int'l case, Justice Thomas famously wrote, "we need not labor to delimit the precise contours of the 'abstract ideas' category in this case."  Instead, he found the claims of patentee Alice...more

USPTO Makes Ex Parte Linden An Informative PTAB Decision

Over five and a half years on from the Supreme Court's Alice vs. CLS Bank ruling, patentees, patent professionals, judges, and USPTO personnel are still wrestling with what it means for an invention to be eligible for...more

MBHB Snippets: A review of developments in Intellectual Property Law - Volume 17, Issue 3

2019 Patent Trial and Appeal Board Key Practice Updates: A Year in Review - 2019 has been an active year for procedural changes in the Patent Trial and Appeal Board (“PTAB”). These changes include not only the PTAB’s...more

USPTO Publishes Update to Its Subject Matter Eligibility Guidance

Early today, October 17, 2019, the U.S. Patent and Trademark Office released an update to its January 2019 Subject Matter Eligibility Guidance.  Unlike the January Guidance, which represented a significant change in how the...more

The PTAB Goes to Europe: Four Recent Section 101 Decisions Designated as Informative

On July 1, the Patent Trial and Appeal Board (PTAB) of the U.S. Patent and Trademark Office (USPTO) designated four of its recent 35 U.S.C. § 101 decisions as informative.  Each of these decisions came down after and applied...more

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