News & Analysis as of

Obviousness

McDermott Will & Emery

When “It’s Obvious” Just Isn’t Enough: Challenger’s Burden to Prove Obviousness

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The US Court of Appeals for the Federal Circuit affirmed the Patent Trial & Appeal Board’s decision that a patent was not obvious because the petitioner failed to show sufficient support of obviousness based on prior art. AMP...more

Jones Day

Federal Circuit Affirms Despite Claim Construction Error

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The Federal Circuit upheld the PTAB’s decision deeming an integrated circuit connector patent unpatentable for obviousness, despite concluding that the Board’s claim construction was erroneous. The Court also rejected a...more

Akin Gump Strauss Hauer & Feld LLP

Federal Circuit: Private Sale by Inventor Does Not Trigger Prior Art Exception Under the AIA

The Federal Circuit affirmed a Patent Trial and Appeal Board (PTAB) final written decision holding that the prior art exception of AIA Section 102(b)(2)(B) does not apply to a prior sale by an inventor when the sale is...more

McDermott Will & Emery

Construing Unambiguous Claim Language and Qualifying Challenged Expert as POSITA

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Addressing the issues of claim construction and the requisite expert qualifications to testify on obviousness and anticipation, the US Court of Appeals for the Federal Circuit vacated a Patent Trial & Appeal Board decision...more

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

Product-by-Process Analysis: Invalidity ≠ Infringement

On March 4, 2025, the Federal Circuit affirmed the Patent Trial and Appeal Board’s (“PTAB”) decision in Restem, LLC v. Jadi Cell, LLC, No. 23-2054, 2025 WL 679195, at *1 (Fed. Cir. Mar. 4, 2025), finding that the patent...more

Knobbe Martens

An Obvious Solution to an Unknown Problem?

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IMMUNOGEN, INC. v. STEWART - Before Lourie, Dyk, and Prost. Appeal from the United States District Court for the Eastern District of Virginia. A solution to a problem can be obvious even when the problem itself was unknown in...more

Knobbe Martens

The Board Must Provide Reasoned Explanation When Discarding Material, Unrebutted Evidence

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CQV CO., LTD. v. MERCK PATENT GMBH - Before Cunningham, Chen, and Mayer. Appeal from the Patent Trial and Appeal Board. The Board erred by failing to explain why it discarded material and unrebutted evidence that a reference...more

Womble Bond Dickinson

Design Patent Obviousness

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The landscape of design patent law has recently evolved with the introduction of a new standard for determining obviousness. For decades, the Rosen-Durling test was used to assess obviousness of design patents....more

Knobbe Martens

Where Method Claim Steps Are Connected by “And,” a Covered Method Must Perform Each Step

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SIERRA WIRELESS, ULC V. SISVEL S.P.A. Before Moore, Schall, and Taranto. Appeal from the Patent Trial and Appeal Board. The Board erred by finding method-claim steps connected by “and” to be conditional and by never...more

Jones Day

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

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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

Mintz - Intellectual Property Viewpoints

Federal Circuit Affirms PTAB’s Analysis Finding Product-by-Process Claim Narrowed During Prosecution Valid Over Prior Art

In a precedential opinion issued on March 4, 2025, in Restem, LLC v. Jadi Cell, LLC, No, 23-2054, the U.S. Court of Appeals for the Federal Circuit affirmed the PTAB’s claim construction and ruling that product-by-process...more

Vorys, Sater, Seymour and Pease LLP

The Precedent: Federal Circuit Vacates Claim Construction But Upholds PTAB’s Determination of Obviousness and Motivation to...

In this edition of The Precedent, we outline the Federal Circuit's decision in HD Silicon Solutions LLC v. Microchip Technology Inc. In HD Silicon Solutions LLC, the Federal Circuit addressed an appeal from the USPTO Patent...more

Alston & Bird

Patent Case Summaries | Week Ending March 7, 2025

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Apple Inc., et al. v. Gesture Technology Partners, LLC, Nos. 2023-1475, -1533 (Fed. Cir. (PTAB) Mar. 4, 2025). Opinion by Prost, joined by Moore and Stoll....more

McDermott Will & Emery

Validity Analysis for Product-by-Process Claim Focuses on Product

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The US Court of Appeals for the Federal Circuit affirmed a Patent Trial & Appeal Board patentability finding, explaining that an anticipation analysis for a product-by-process claim focuses on the product and not the process....more

McDermott Will & Emery

Inventor’s Motivation to Combine Does Not Control Obviousness

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The US Court of Appeals for the Federal Circuit affirmed a district court decision rejecting claims of a patent application directed to a dosing regimen for a cancer treatment, finding the claims to be obvious where the...more

McDonnell Boehnen Hulbert & Berghoff LLP

Regeneron Pharmaceuticals, Inc. v. Mylan Pharmaceuticals Inc. (Fed. Cir. 2025)

Completing a recent jurisprudential "hat trick,"* the Federal Circuit affirmed a District Court grant of a preliminary injunction against a biosimilar applicant for Regeneron's EYLEA biologic drug in Regeneron...more

McDonnell Boehnen Hulbert & Berghoff LLP

Immunogen, Inc. v. Stewart (Fed. Cir. 2025)

After creating something of a frisson due to the apprehension that the Federal Circuit might be convinced to re-evaluate whether it was a necessary element for establishing obviousness for the skilled artisan to have had a...more

Knobbe Martens

Federal Circuit Review | February 2025

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In HD Silicon Solutions LLC V. Microchip Technology Inc., Appeal No. 23-1397, the Federal Circuit held that  all but one patent claim were invalid as obvious because the claimed material, as properly construed, was disclosed...more

Foley & Lardner LLP

Leveraging USPTO Delays To Maximize Patent Term

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Before the USPTO was subject to a hiring freeze, it assumed it would onboard 400 new examiners between fiscal year 2025 and fiscal year 2026, and still predicted an increase in the backlog of unexamined patent applications....more

Polsinelli

Federal Circuit Affirms District Court’s Obviousness Judgment on ImmunoGen Patent Application

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1. Background: ImmunoGen’s Patent Application & Dispute - In 2014, ImmunoGen, Inc. (Immunogen) filed U.S. Patent Application No. 14/509,809 (the ’809 application)....more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases: Apple Inc. v. Gesture Technology Partners

Apple Inc. v. Gesture Technology Partners, LLC, Appeal Nos. 2023-1475, -1533 (Fed. Cir. Mar. 4, 2025) Our Case of the Week is a high-stakes appeal from an inter partes review concerning a patent titled “Camera Based...more

MoFo Life Sciences

Navigating Obviousness: Federal Circuit Addresses Patentability of Pharmaceutical Dosing Methods

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On March 6, 2025, the United States Court of Appeals for the Federal Circuit (“Federal Circuit”) issued a precedential decision in ImmunoGen, Inc. v. Stewart, in which the court clarified its standards for determining...more

Kilpatrick

COVID-19 Vaccine Patent War: Moderna's Claims Invalidated by PTAB

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The door may now be open for additional challenges to patents covering mRNA vaccine technologies, paving the way for increased competition in the mRNA vaccine space. On Wednesday, March 5, 2025, the United States Patent...more

Jones Day

PTAB Retains Jurisdiction Of Expired Patents

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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

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

PTAB Year in Review – Caveat Experimenter: Using Experimental Data in PTAB Proceedings Comes With Risks

Parties involved in Patent Trial and Appeal Board (PTAB) proceedings sometimes contemplate submitting experimental data to support their positions. Although such data can be useful, there also are risks. Several recent cases...more

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