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Inter Partes Review (IPR) Proceeding Obviousness Printed Publications

Jones Day

Availability of Document on Government Website Insufficient for Institution

Jones Day on

In denying inter partes review in OBM, Inc. & Cholla Energy LLC v. Lancium LLC, the PTAB again made clear that “technical availability” of a reference is not enough to establish it is a printed publication. Here, the PTAB...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

Sterne, Kessler, Goldstein & Fox P.L.L.C.

2021 PTAB Year in Review: Analysis & Trends

[co-author: Jamie Dohopolski] Love it or hate it, ignore the USPTO Patent Trial and Appeal Board (PTAB) at your peril. The introduction of the PTAB as part of the America Invents Act over ten years ago has forever changed...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Federal Circuit Appeals from the PTAB and ITC: Summaries of Key 2021 Decisions

[co-author: Jamie Dohopolski] Last year, the continued global COVID-19 pandemic forced American courts to largely continue the procedures set in place in 2020. The U.S. Court of Appeals for the Federal Circuit was no...more

McDonnell Boehnen Hulbert & Berghoff LLP

Qiagen North America Holdings Inc. v. Handylab, Inc. (Fed. Cir. 2021)

The inter partes review (IPR) provisions of the Leahy-Smith America Invents Act have been castigated by many for the propensity of the Patent Trial and Appeal Board (PTAB) to find claims challenged in these proceedings to be...more

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

Mixed Result in M&K Holdings v. Samsung Electronics: Federal Circuit Finds Anticipation not Necessarily Inherent in Obviousness...

Earlier this month, in the precedential decision M & K Holdings v. Samsung Electronics Co., the Court of Appeals for the Federal Circuit (“the CAFC”) upheld the Patent Trial and Appeal Board (“the Board”) in finding certain...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

PTAB Strategies and Insights - February 2021: M&K Holdings v. Samsung

Samsung sought inter partes review of M&K’s U.S. Patent No. 9,113,163. The Board held all claims unpatentable. M&K appealed, arguing that the Board erred by relying on references that do not qualify as prior art printed...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

PTAB Strategies and Insights - February 2021

[co-author: Kathleen Wills] The PTAB Strategies and Insights newsletter provides timely updates and insights into how best to handle proceedings at the USPTO. It is designed to increase return on investment for all...more

McDermott Will & Emery

If You Seek or Browse and Can Find, It’s Publicly Available, but Anticipation Isn’t Obvious and Requires Notice

McDermott Will & Emery on

The US Court of Appeals for the Federal Circuit found that facilitating browsing of documents on a website was sufficient to support public accessibility of prior art references, but that the Patent Trial and Appeal Board...more

Knobbe Martens

Evidence Supports Prior Art’s Public Accessibility but Not the Board’s Adoption of an Unpresented Theory of Anticipation

Knobbe Martens on

M & K HOLDINGS, INC. v. SAMSUNG ELECTRONICS CO., LTD. Before Moore, Bryson, and Chen. Appeal from the Patent Trial and Appeal Board. Summary: Title-searchable publications shared on a prominent standards-setting...more

Knobbe Martens

Joining an IPR Triggers IPR Estoppel Only for Instituted Grounds

Knobbe Martens on

NETWORK-1 TECHNOLOGIES, INC. v. HEWLETT-PACKARD COMPANY, HEWLETT PACKARD ENTERPRISE COMPANY - Before Prost, Newman, and Bryson. Appeal from the United States District Court for the Eastern District of Texas. Summary: A...more

Akin Gump Strauss Hauer & Feld LLP

PTAB Ruling Highlights a Petitioner’s Burden for Qualifying an Internet Screenshot as a “Printed Publication”

In a recent decision issued in Louisiana-Pacific Corp. v. Huber Engineered Woods LLC, the Patent Trial and Appeal Board addressed the showing that a petitioner for inter partes review must make to demonstrate that an asserted...more

Akin Gump Strauss Hauer & Feld LLP

USPTO Issues Guidance on “Applicant Admitted Prior Art” in IPRs

In an August 18 memorandum, the U.S. Patent and Trademark Office (USPTO) issued binding agency guidance on the proper role of “applicant admitted prior art” (AAPA) in inter partes review (IPR) proceedings. The memorandum...more

Mintz - Intellectual Property Viewpoints

“Anything Goes” – Federal Circuit Says PTAB Can Use Any Means to Knock Out Substitute Claims (Uniloc v. Hulu: Part 2)

Yesterday we discussed the Federal Circuit’s decision in Uniloc 2017 LLC v. Hulu, LLC confirming the Board’s authority to review contingent substitute claims after the original claims have been held invalid by a federal...more

Haug Partners LLP

Uniloc v. Hulu - Federal Circuit Clash over Scope of PTAB Review of Substitute Claims

Haug Partners LLP on

WHAT DO WE KNOW? 1. On July 22, 2020, a sharply split Federal Circuit panel held that “[t]he PTAB correctly concluded that it is not limited by § 311(b) in its review of proposed substitute claims in an IPR, and that it...more

Akin Gump Strauss Hauer & Feld LLP

Far-Reaching Effect of IPR Estoppel Dooms Invalidity Defense Based on Prior Art Product

Chief Judge Stark granted a patent owner’s motion for summary judgment of inter partes review (IPR) estoppel, holding that obviousness defenses based on a prior art product could not be asserted because a prior art...more

Knobbe Martens

PTAB Cannot Institute IPR on PTAB-Created Grounds

Knobbe Martens on

KONINKLIJKE PHILIPS N.V. v. GOOGLE LLC - Before Prost, Newman, and Moore. Appeal from Patent Trial and Appeal Board. Summary: The Board can institute IPR only on grounds raised in a petition. Additionally, the Board...more

Akin Gump Strauss Hauer & Feld LLP

Calling a Printed Publication a “System” is Not Enough to Avoid IPR Estoppel

A Central District of California judge recently granted summary judgment of no obviousness based on inter partes review (IPR) estoppel because the only prior art references used to challenge patent validity could have been...more

WilmerHale

Precedential Opinion Panel Clarifies Reasonable Likelihood Standard for Printed Publications at the Institution Stage of...

WilmerHale on

On December 20, 2019, the Precedential Opinion Panel (POP) of the Patent Trial and Appeal Board (PTAB) issued its decision in IPR2018-01039, addressing “What is required for a petitioner to establish that an asserted...more

Foley & Lardner LLP

District Court Sheds Light on Scope of IPR Estoppel

Foley & Lardner LLP on

One area of estoppel arising from an unsuccessful AIA petition that remains poorly understood relates to prior art that is described both in a printed publication or patent and also was in use by others, such as to create...more

Jones Day

325(d) And Printed Publication Issues Doom Petition

Jones Day on

The most persuasive IPR petitions offer fresh unpatentability theories never considered before. But petitions that simply repackage old issues often don’t gain traction. So, when you’re citing prior art that was before the...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

2019 Report: Federal Circuit Appeals from the PTAB - Summaries of Key 2018 Decisions

In 2018, the U.S. Court of Appeals for the Federal Circuit docketed close to 600 appeals from the U.S. Patent and Trademark Office (USPTO). That is the second highest number since starting to hear post-American Invents Act...more

WilmerHale

Federal Circuit Patent Updates - September 2018

WilmerHale on

Hyatt v. Pato (No. 2017-1722, 9/24/18) (Reyna, Wallach, Hughes) - Hughes, J. Reversing dismissal for lack of subject matter description stating, “the exclusive jurisdiction of this court and the Eastern Virginia district...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases - September 2018 #3

PATENT CASE OF THE WEEK - Acorda Therapeutics, Inc. v. Roxane Laboratories, Inc., Appeal Nos. 2017-2078, -2134 (Fed. Cir. Sept. 10, 2018) The Federal Circuit affirmed the district court’s ruling following a bench trial,...more

Knobbe Martens

Federal Circuit Review - July 2018

Knobbe Martens on

Determining Whether a Claim Element or Combination of Elements Would Have Been Well-Understood, Routine, and Conventional Is a Question of Fact - In Aatrix Software, Inc. v. Green Shades Software, Inc., Appeal No....more

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