News & Analysis as of

Claim Limitations Obviousness

Rothwell, Figg, Ernst & Manbeck, P.C.

Brave New World: UPC Central Division’s First Opinion is a Revocation of Antibody Claims as Lacking Inventive Step

Following the U.S. Supreme Court’s invalidation of a counterpart U.S. patent in the same family for lack of enablement (21-757 Amgen Inc. v. Sanofi (05/18/23) (supremecourt.gov)), the UPC has now rendered a decision on its...more

Robins Kaplan LLP

Bausch Health Ireland Ltd. v. Padagis Israel Pharms. Ltd.,

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Case Name:  Bausch Health Ireland Ltd. v. Padagis Israel Pharms. Ltd., No. CV 20-5426 (SRC), 2022 WL 17352334 (D.N.J. Dec. 1, 2022) (Chesler, J.)  Drug Products and Patent(s)-in-Suit: Duobrii® (halobetasol...more

Robins Kaplan LLP

Arius Two, Inc. v. Alvogen PB Rsch. & Dev. LLC - Belbuca® (Buprenorphine)

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Case Name: Arius Two, Inc. v. Alvogen PB Rsch. & Dev. LLC, No. 2022-1394, 2022 WL 17828352 (Fed. Cir. Dec. 21, 2022) (Circuit Judges Chen, Clevenger, and Cunningham presiding; Opinion by Chen, J.) (Appeal from D. Del.,...more

Robins Kaplan LLP

Tris Pharma, Inc. V. Teva Pharms. Usa, Inc., Quillichew Er® (Methylphenidate)

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Case Name: Tris Pharma, Inc. v. Teva Pharms. USA, Inc., Civ. No. 20-5212 (KM)(ESK) (D.N.J. Aug. 16, 2022) (McNulty, J.)  Drug Product and Patent(s)-in-Suit: QuilliChew ER® (methylphenidate); U.S. Patents Nos. 9,545,399 (“the...more

Akin Gump Strauss Hauer & Feld LLP

PTAB: Statements About Device Not Disclosed in a Video Are Not Prior Art; Concurrence: Video Itself—If Publicly Available—Is Prior...

The Patent Trial and Appeal Board denied a petition to institute inter partes review, finding there was no reasonable likelihood that petitioners would prevail on their obviousness challenges. In rendering its decision, the...more

McDonnell Boehnen Hulbert & Berghoff LLP

Tris Pharma, Inc. v. Actavis Laboratories FL, Inc. (Fed. Cir. 2022)

Almost four years ago, in a relatively rare occurrence based on there being an insufficient factual record to permit proper appellate review, the Federal Circuit vacated a District Court decision rendering invalid the claims...more

McDonnell Boehnen Hulbert & Berghoff LLP

Novartis Pharmaceuticals Corp. v. Accord Healthcare, Inc. (Fed. Cir. 2022)

The Federal Circuit recently granted a panel rehearing and vacated a panel decision between these parties decided earlier this year (see Novartis Pharmaceuticals Corp. v. Accord Healthcare), and rendered a decision that...more

Knobbe Martens

Federal Circuit Review - March 2022

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Claim Limitation Not Disclosed by Any Reference but Disclosed by “Proposed Combination” of References Is Obvious - In Hoyt Augustus Fleming v. Cirrus Design Corporation, Appeal No. 21-1561, the Federal Circuit held that a...more

Haug Partners LLP

Federal Circuit Clarifies the Nexus Requirement for Objective Indicia of Nonobviousness

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In Quanergy Systems, Inc. v. Velodyne Lidar USA, Inc.1, a Panel of the U.S. Court of Appeals for the Federal Circuit affirmed the Patent Trial and Appeal Board’s (PTAB or Board) decisions that claims of a Velodyne patent were...more

McDermott Will & Emery

Count On It, Plural Term Means More Than One

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The US Court of Appeals for the Federal Circuit affirmed Patent Trial & Appeal Board (Board) patentability decisions after determining that the Board did not err in construing multiple terms within the challenged patents....more

Morrison & Foerster LLP - Federal Circuitry

Last Two Weeks in the Federal Circuit (December 27 - January 7)

The Federal Circuit is holding its first argument session of 2022 this week (with a return to telephonic arguments in light of the Omicron variant).  In this post, we take a look back at how the Court closed out 2021 and...more

Haug Partners LLP

Belcher Pharmaceuticals’ Patent Held Unenforceable by the Federal Circuit

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The Federal Circuit published a precedential decision on September 1, 2021 regarding the unenforceability of a pharmaceutical patent due to inequitable conduct. In Belcher Pharmaceuticals LLC v. Hospira, Inc., the Court...more

McDonnell Boehnen Hulbert & Berghoff LLP

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

Morrison & Foerster LLP - Federal Circuitry

Last Week in the Federal Circuit (May 24-28): Once A Granted Patent, Always a Granted Patent?

We hope our readers had a restful Memorial Day Weekend. Even DC’s cicadas took the weekend off. Before the long weekend, the Federal Circuit left us with 3 precedential opinions, including one addressing what qualifies as...more

McDonnell Boehnen Hulbert & Berghoff LLP

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

Haug Partners LLP

Teaching Away and No Reasonable Expectation of Success Arguments Insufficient to Avoid Obviousness Affirmance by the Federal...

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In Trustees of Columbia University v. Illumina, Inc., the U.S. Court of Appeals for the Federal Circuit affirmed the Patent Trial and Appeals Board (“PTAB” or “Board”) decision to invalidate five patents owned by Columbia,...more

Mintz - Intellectual Property Viewpoints

Tip #5 for Avoiding IPR Institution: Policing KSR’s motivation requirement for the ‘how’ and ‘why’.

Building on Tip #4, one effective way to avoid institution and not address facts is to point out shortcomings in the petition's application of KSR when asserting motivation to combine for an obviousness analysis. The Patent...more

Goodwin

ITC 337 Quarterly Insider Q2 2020

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Goodwin’s 337 Quarterly Insider remains the premiere publicly available source for keeping up to date on all meaningful decisions coming out of the Commission. Please find below Goodwin’s insights on the months of April, May,...more

Knobbe Martens

Federal Circuit Review - June 2020

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Non-Infringement Need Not Be “Actually Litigated” To Shield Accused Products From Infringement Liability In Subsequent Actions - In In Re Personal Web Technologies LLC, Appeal No. 19-1918, the Federal Circuit ruled that the...more

Mintz - Intellectual Property Viewpoints

Filling the Hole with Common Sense: When Evidentiary Support is Adequate

The Federal Circuit recently reaffirmed a case where common sense was used to supply a missing element in a § 103 obviousness analysis. On June 26, 2020, the Federal Circuit issued a decision in B/E Aerospace, Inc. v. C&D...more

Knobbe Martens

Preamble Found Limiting Where It Supplied Antecedent Basis for Other Claim Limitations

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SHOES BY FIREBUG LLC v. STRIDE RITE CHILDREN'S GROUP - Before Lourie, Moore, and O’Malley. Appeal from the Patent Trial and Appeal Board. Summary: In similar claims of two related patents, one preamble was limiting...more

Akin Gump Strauss Hauer & Feld LLP

Federal Circuit: PTAB May Not Institute on Grounds Left out of IPR Petition

The Federal Circuit recently addressed whether the Patent Trial and Appeal Board (PTAB) can institute inter partes review (IPR) on a ground not advanced by the petitioner, as well as whether the general knowledge of a person...more

Katten Muchin Rosenman LLP

Federal Circuit Issues Opinion on "Inherent Obviousness" in Patent Claim, Invalidating Orange Book Listed Pharma Patent

Key Points - Federal Circuit issued precedential opinion in Hospira Inc. v. Fresenius Kabi USA, LLC that affirmed obviousness of a liquid drug patent claim, encouraging future patent challengers to raise the issue of...more

Knobbe Martens

Federal Circuit Review - November 2019

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The Appointments Clause: Ensuring That PTAB Decisions Are Subject to Constitutional Checks and Balances  In Arthrex, Inc. v. Smith & Nephew, Inc., Appeal No. 18-2251, the Federal Circuit ruled that, under the then-existing...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases - August 2019 #3

PATENT CASE OF THE WEEK - Nalpropion Pharmaceuticals, Inc. v. Actavis Laboratories, FL, Inc., Appeal No. 2018-1221 (Fed. Cir. Aug. 15, 2019) - This week’s Case of the Week focuses on issues relating to written...more

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