News & Analysis as of

Obviousness

McDermott Will & Emery

Chromatographic Clash: When Is a Lead Compound Analysis Even Necessary?

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The US Court of Appeals for the Federal Circuit affirmed the Patent Trial & Appeal Board’s determination that 79 challenged composition claims across three related patents were unpatentable but reversed the Board’s...more

McDermott Will & Emery

Plausible Alternative Understanding of Prior Art? So What?

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Affirming the Patent Trial & Appeal Board’s final determination that three claims were invalid for obviousness, the US Court of Appeals for the Federal Circuit ruled that a “plausible alternative understanding” of the prior...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases - December 2024

Mirror Worlds Technologies, LLC v. Meta Platforms, Inc., Appeal Nos. 2022-1600, -1709 (Fed. Cir. Dec. 4, 2024) In this appeal from the United States District Court for the Southern District of New York, the Federal...more

Dinsmore & Shohl LLP

Christmas Came Early – USPTO Withdraws Proposed Rule on Terminal Disclaimers

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Patent owners with robust continuation filing strategies can breathe a sigh of relief as the United States Patent and Trademark Office (“USPTO”) has withdrawn a proposed rule, which would have weakened patents linked to one...more

Morgan Lewis

USPTO Withdraws Proposed Terminal Disclaimer Rule

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The United States Patent and Trademark Office (USPTO) has withdrawn a proposed rule for filing terminal disclaimers to overcome obviousness-type double patenting rejections. The proposed rule would likely have had wide...more

Womble Bond Dickinson

Unexpected Results in Hatch Waxman Litigation: A Review of Legal Decisions from 2023

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Patent owners generally look to secondary indicia to bolster their nonobvious defenses when prior art and/or knowledge of a person of ordinary skill in the art (“POSA”) seem to make the obviousness decision a close call. This...more

Erise IP

Eye on IPRs: November 2024: USPTO Director to Step Down, Did Fed. Circuit DISH Asks Full Fed. Cir. Panel to Reconsider Vacating...

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Every month, Erise’s patent attorneys review the latest inter partes review cases and news to bring you the stories that you should know about: USPTO Director Vidal to Step Down - On November 12, Under Secretary of...more

Robins Kaplan LLP

Purdue Pharma L.P v. Accord Healthcare Inc. - OxyContin® (oxycodone HCl)

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Case Name: Purdue Pharma L.P v. Accord Healthcare Inc., Civ. No. 22-913-WCB, 2024 WL 4120717 (D. Del. Sept 9, 2024) (Bryson, J.) Drug Product and Patent(s)-in-Suit: OxyContin® (oxycodone HCl); U.S. Patent No. 11,304,908 (“the...more

Mintz - Intellectual Property Viewpoints

The New Rubric for Obviousness-Type Double Patenting

The basis for obviousness-type double patenting (ODP) is found in 35 U.S.C. § 101, establishing an applicant is entitled to a single patent, “a patent” or the “first” patent, for an invention....more

MoFo Life Sciences

Establishing Unexpected Results: PTAB Highlights Pitfalls For Rule 132 Declarations

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A recent decision by the Patent Trial and Appeal Board (PTAB) sheds light on certain pitfalls patent applicants may encounter when submitting declarations under 37 C.F.R. § 1.132 (“Rule 132 Declarations”). Rule 132...more

DLA Piper

Effect of Patent Term Extensions on Obviousness-type Double Patenting

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The US Court of Appeals for the Federal Circuit issued its opinion in Allergan USA, Inc. v. MSN Laboratories Private Ltd., No. 24-1061 (Fed. Cir. 2024), holding that “a first-filed, first-issued, later-expiring claim cannot...more

Fitch, Even, Tabin & Flannery LLP

[Webinar] Navigating the Changes to the Test for Obviousness in Design Patents After LKQ Corp. v. GM Global - October 29th, 9:00...

Please join Fitch Even for a free webinar, “Navigating the Changes to the Test for Obviousness in Design Patents After LKQ Corp. v. GM Global,” on Tuesday, October 29, at 9:00 a.m. PDT / 10:00 a.m. MDT / 11:00 a.m. CDT / 12...more

Fitch, Even, Tabin & Flannery LLP

IP Alert: Allergan Limits Cellect, But Leaves Ambiguity in ODP Analysis

On August 13, the Federal Circuit, in Allergan USA, Inc. v. MSN Laboratories Private Ltd., held that a “first-filed, first-issued, later-expiring claim cannot be invalidated by a later-filed, later-issued, earlier-expiring...more

Jones Day

Supreme Court Denies Cellect Petition on Interplay Between PTA and ODP

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The Supreme Court denies Cellect LLC's petition for certiorari to consider whether patent term adjustment ("PTA") should be included in patent term for obviousness-type double patenting ("ODP") purposes....more

Venable LLP

PTAB Grants Institution of Eight IPRs challenging The Johns Hopkins University Pembrolizumab Patents

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Earlier this year, Merck Sharp & Dohme, LLC (“Merck”) requested inter partes review (“IPR”) of a number of patents owned by the Johns Hopkins University (“JHU”). ...more

International Lawyers Network

Can Design Patents Be Invalidated?

Suppose you have a design for an ornamental appearance of an article and start producing the article. Subsequently, you receive notice from an owner of a design patent that you are infringing their patent. You conduct a prior...more

Jones Day

Director Vacates Decision Based on Improper Claim Construction

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The PTAB denied institution of inter partes review reasoning that Petitioner did not demonstrate a reasonable likelihood that Petitioner would prevail in establishing the unpatentability of any of the challenged claims. The...more

Patterson Belknap Webb & Tyler LLP

Half-Zipped: Judge Chen Grants Summary Judgment of Non-Obviousness and Partial Summary Judgment of Non-Infringement on Garment...

United States District Judge Pamela K. Chen (E.D.N.Y.) recently granted Plaintiff Shaf International, Inc. (“Shaf”)’s motion for summary judgment of validity of U.S. Patent No. 10,433,598 (the “’598 Patent”) and Defendant...more

Katten Muchin Rosenman LLP

Stating the Obvious - Katten Kattwalk | Issue 28

The Federal Circuit overturned its 42-year-old obviousness test for designs. Fashion companies, take note. The shape of a handbag, the red sole of a shoe: for fashion companies, design patents have long played a role in...more

Jones Day

PTAB Issues First Post-LKQ Design Patent Decision

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On August 6, 2024, the PTAB issued its first written decision applying a new test for obviousness of design patents. In Next Step Group, Inc. v. Deckers Outdoor Corp., IPR2024-00525, Paper 16 (P.T.A.B. Aug. 6, 2024)...more

A&O Shearman

Federal Circuit Provides Clarity On Proper Obviousness-Type Double Patenting References

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In Allergan USA, Inc. et al., v. MSN Laboratories Private Ltd., et al., the United States Court of Appeals for the Federal Circuit issued a precedential decision relating to obviousness-type double patenting (“ODP”) and...more

McDonnell Boehnen Hulbert & Berghoff LLP

Astellas Pharma, Inc. v. Sandoz Inc. (Fed. Cir. 2024)

One of the anticipated consequences of the Supreme Court's Loper decision is that it will unleash judges to impose their statutory interpretations of administrative agencies' applications of the law within their areas of...more

Knobbe Martens

An Expert Witness Need Not Have Been a Posita at the Time of the Invention

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Before Dyk, Clevenger, and Stoll.  Appeal from the United States District Court for the District of Delaware. Summary: An expert witness can testify from the perspective of a POSITA at the time of the invention even if they...more

Knobbe Martens

Federal Circuit Review | August 2024

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Specify the Steps of Information Manipulation or Lose under § 101 - In Mobile Acuity Ltd. v. Blippar Ltd. Appeal No. 22-2216, the Federal Circuit held that patent claims that merely recite result-orientated, functional...more

Irwin IP LLP

Double Trouble? Some Double Patenting Woes Resolved 

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Allergan USA v. MSN Laboratories Private Ltd., No. 2024-1061 (Fed. Cir. Aug. 13, 2024) - On August 13, 2024, the Federal Circuit reversed a district court’s decision that a patent was invalid for obviousness-type double...more

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