News & Analysis as of

Additional Discovery

Akin Gump Strauss Hauer & Feld LLP

Withholding Data That PTAB Would Deem Relevant to Patentability Supports Adverse Judgment in an IPR

The Patent Trial and Appeal Board (PTAB) granted Petitioner’s motions to sanction Patent Owner for failure to meet its duty of candor and fair dealing in five related inter partes review  proceedings. The PTAB found that...more

Jones Day

PTAB Denies Discovery of Draft Declaration

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On November 18, 2022, a panel of three PTAB administrative patent judges denied a Patent Owner’s Request for Additional Discovery in Twitter, Inc. v. Palo Alto Research Center Inc., IPR2021-01398. The PTAB found that...more

Jones Day

PTAB Reiterates Requirements for Additional Discovery

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The PTAB in a recent PGR proceeding: SWM International, LLC et al v. DynaEnergetics Europe GmbH (PGR2021-00097), reiterated the requirements for additional discovery. In particular, in this matter, the petitioner, having...more

Jones Day

Motion for Additional Discovery Based on Unraised Arguments Denied

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The Patent Trial and Appeal Board (“PTAB”) recently denied a Petitioner’s Motion for Additional Discovery. Scientific Design Co., Inc. v. Shell Oil Co., IPR2021-01537, Paper 18 (PTAB Aug. 12, 2022). In an inter partes review...more

Akin Gump Strauss Hauer & Feld LLP

PTAB Orders Production of Final Infringement Contentions from Related Litigations Because they were Inconsistent with Patent...

Petitioners moved for an order requiring Patent Owner to produce discovery comprising Final Infringement Contentions from related district court litigations between the parties.  Petitioners set forth two independent bases...more

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Discovery Request Seeking Deposition Preparation Materials Denied

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The Patent Trial and Appeal Board (“PTAB”) recently denied a Motion for Additional Discovery because the movant could not prove beyond mere speculation that the requested documents would be useful to show witness scripting....more

Hinshaw & Culbertson LLP

The LHD/ERISA Advisor: ERISA Exhaustion Requirement Not Satisfied by Verbal Appeal When Plan Required Written Appeal

In Ligotti v. United Healthcare Services, 2021 U.S. Dist. LEXIS 106992 (S.D. Fla., June 8, 2021), a Florida district court held that a health care provider challenging claim denials on behalf of his patients cannot satisfy...more

Mintz - Intellectual Property Viewpoints

Patent Owner Tip #9 for Surviving an Instituted IPR: Issues Warranting Limited Additional Discovery

In our previous post we started talking about discovery procedures in inter partes review (“IPR”) proceedings under 37 CFR § 42.51 and, in particular, the scope and timing of seeking limited additional discovery under Rule...more

Mintz - Intellectual Property Viewpoints

Patent Owner Tip #8 for Surviving an Instituted IPR: Additional Discovery is Possible, but Should be Carefully Planned

Discovery procedures in inter partes review (“IPR”) proceedings, governed by 37 CFR § 42.51, are more limited in scope and timing compared to cases in district court. There are three types of discovery at the Patent Trial...more

Jones Day

In Your Dreams – Additional PTAB Discovery Remains Elusive

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Discovery in an IPR proceeding is limited compared to district court litigation in order to focus the proceedings and promote speed and efficiency. The PTAB Practice Guide and 37 C.F.R 42.51 provide for three types of...more

Proskauer - Minding Your Business

Bearing the Books and Records Burden: Delaware Supreme Court Affirms Section 220 Order in AmerisourceBergen

This past year, Proskauer’s private fund litigation blog highlighted a Delaware Chancery case adopting an expansive view in favor of parties seeking information from companies under Section 220 of the Delaware General...more

McDonnell Boehnen Hulbert & Berghoff LLP

PTAB Grants CVC Motion for Marraffini Deposition

The Patent Trial and Appeal Board (PTAB) entered an Order on Tuesday regarding the motion by Junior Party the University of California/Berkeley, the University of Vienna, and Emmanuelle Charpentier (collectively, "CVC") in...more

McDonnell Boehnen Hulbert & Berghoff LLP

Broad Files Motion Opposing CVC's Motion to Subpoena Witnesses

At the end of October, in Interference No. 106,115 between Senior Party The Broad Institute, Harvard University, and the Massachusetts Institute of Technology (collectively, "Broad") and Junior Party the University of...more

Proskauer - Minding Your Business

To the Victor Go the Spoliation Sanctions: Eastern District of Louisiana Exercises Inherent Power to Issue Sanctions for...

Parties should think twice before posting potential evidence on social media, as the Plaintiff in Guarisco v. Boh Brothers Construction learned recently. The Eastern District of Louisiana imposed sanctions on Plaintiff for...more

Proskauer - Minding Your Business

CCP 2031.280(a): New Document Production Obligations in California Civil Litigation

Effective as of January 1, 2020, all civil litigants in California will have additional discovery burdens. The California Code of Civil Procedure now requires “[a]ny documents or category of documents produced in response to...more

Akin Gump Strauss Hauer & Feld LLP

PTAB Orders Production of Raw Data and Instructions Underlying Test Results

The Patent Trial and Appeal Board (PTAB) recently issued an Order that illustrates the circumstances in which a party may obtain additional discovery in an inter partes review (IPR). In Apple Inc. v. Singapore Asahi Chemical...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

Jones Day

Trial Practice Guide Updates – Discovery, Testimony, Motions to Amend, and Joinder

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Our prior post on the PTAB’s second update to the AIA Trial Practice Guide (TPG), published July 15, 2019, highlighted the additional guidance provided for petitions, patent owner preliminary responses and claim construction....more

Jones Day

Trial Practice Guide Updates – Multiple Petitions, Claim Construction, and PO Testimonial Evidence

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On July 15, 2019, the USPTO’s Patent Trial and Appeal Board (PTAB) published a second update to the AIA Trial Practice Guide (TPG) (“2nd Update”), providing additional guidance for trial practice before the Board. The...more

Knobbe Martens

USPTO Publishes PTAB Trial Practice Guide Update

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On July 14, 2019, the USPTO published a second update to the AIA Trial Practice Guide with additional guidance about trial practice before the Board. This latest update, while lengthy, does not introduce many significant...more

Jones Day

PTAB Orders Petitioner’s Expert to Produce Discovery

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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

Womble Bond Dickinson

One Star Rating: Court Denies Uber’s Motion to Compel Arbitration after Failing to Authenticate Agreement

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A District Court in California denied Uber’s motion to arbitrate a TCPA class action claim after the ride-sharing company failed to authenticate the information from its database that allegedly confirmed the arbitration...more

Jones Day

Board Grants Discovery Regarding RPI Issues

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In Cavium, LLC v. Alacritech, Inc., Case IPR2018-00401 (PTAB Nov. 20, 2018) (Paper 24), the PTAB granted a Patent Owner’s motion for additional discovery relating to real party-in-interest. The split-panel decision is...more

Jones Day

Seeking District Court Assistance For An IPR Proceeding

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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

Jones Day

PTAB Grants Rare Motion for Additional Discovery

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The PTAB recently granted a rare motion for additional discovery into the question of whether an unnamed party, Amneal Pharmaceuticals, LLC (“Amneal”), should have been named as a real-party-in-interest. In Kashiv LLC v....more

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