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  • Ipr2025-01336Institution denied
    PTAB · Feb 10, 2026 · IPR2025-01336 · APJ John A Squires · IPR · Institution

    The Board denied institution of IPR2025-01336 because the petitioner failed to show a reasonable likelihood of prevailing on at least one challenged claim.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition. Accordingly, institution of inter partes review or post-grant review is denied in the following proceedings: IPR2025-01313 IPR2025-01336” slip op. at 2

    None
    Patents in suitUS 9,734,825
  • Ipr2025-01313Institution denied
    PTAB · Feb 10, 2026 · IPR2025-01313 · IPR · Institution

    Institution of IPR2025-01313 was denied because the petitioner failed to show a reasonable likelihood of prevailing on at least one challenged claim.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition. Accordingly, institution of inter partes review or post-grant review is denied in the following proceedings: IPR2025-01313 IPR2025-01336” slip op. at 2

    None
    Patents in suitUS 10,783,228
  • PTAB · Feb 9, 2026 · IPR2025-00750 · APJ Benjamin D M Wood · IPR · Rehearing

    The Board denied rehearing, leaving institution denied because Petitioner did not show a reasonable likelihood of prevailing on claims 1–22 under the challenged obviousness grounds.

    RulingsRehearing decision
    • RehearingRehearing, deniedDenied

      “Petitioner misstates the Decision’s reasoning. As is clear from the previous discussion, we determined that Petitioner’s articulated reasons for combining EP’536 with CN’180 lacked a rational underpinning, not because “EP’536 does not relate to ‘air bags,’” but because the means by which EP’536’s device inflates differs fundamentally from that of CN’180’s device. Dec. 17–18. Petitioner did not acknowledge this critical difference in the Petition, and continues not to do so in its Rehearing Request.” slip op. at 5

    • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentable

      “EP’536 with CN’180 lacked a rational underpinning because EP’536’s inflation mechanism differs fundamentally from CN’180’s inflation mechanism. Dec. 17–18. As we stated, whereas CN’180’s fall-protection belt uses an airbag that requires an external source of pressurized air to inflate, EP’536’s garment does not need an external inflation device because “the gas generating agent 18 in each envelope automatically generates gas and inflates the envelopes in response to rising temperatures.” Id. at 18 (citing Ex. 1004 ¶ 15; Ex. 1005 ¶¶ 5, 19). This difference reflects the fundamentally different purposes of the two devices: CN’180’s device is designed to provide “fall protection” to, e.g., “elderly people,” (Ex. 1005 ¶ 1, 3), whereas EP’536’s device provides “adaptive thermal insulation” for, e.g., garments worn by fire fighters. Ex. 1004 ¶¶ 1–3, 250. Because of the different means by which EP’536’s and CN’180’s devices inflate and the different purposes for doing so, we were not persuaded that one of ordinary skill in the art would have combined the references as Petitioner proposed. Dec. 18. We further noted that the modification would not have improved the reusability of EP’536’s device “by having only one mechanism to recharge,” because EP’536’s “gas generating agent does not need any ‘mechanism to recharge.’” Dec. 18. Instead, we noted EP’536’s teaching that its gas generating agent “automatically recombines or condenses in response to a temperature decrease to return the envelopes, and therefore the garment, to its original thickness, at which point the gas generating agent is ready for subsequent reactivation.” Id. (citing Ex. 1004 ¶¶ 139–141). Finally, we determined that replacing EP’536’s envelopes with CN’180’s airbag “would have made EP’536’s invention unsuitable for its intended purpose: providing a protective garment with ‘adaptive thermal insulation.’” Dec. 19. We stated that “Petitioner does not suggest, and we have found nothing in the record to establish, that CN’180’s airbag would provide this feature.” Id. at 20.” slip op. at 3

    • Obviousness (§103) › KSR rationalesMotivation not foundNot shown unpatentable

      “rationales for combining EP’536 and CN’180. Reh’g Req. 6–7. First, Petitioner asserts that we “improperly rejected Petitioner’s ‘simple substitution’ evidence in view of [the Board’s] incorrect conclusion that EP’536 does not disclose an ‘external source of inflation [EP’536’s dosing aids].’” Id. at 6 (citing Dec. 18–19). This argument is unpersuasive at least because, as we discussed above, EP’536’s dosing aids do not constitute an external source of inflation. Petitioner further argues that we incorrectly evaluated its “obvious to try” rationale because, contrary to our analysis, Petitioner did in fact identify a problem to be solved by its “finite number of solutions”: “simplify[ing] the design and reduc[ing] the number of required inflation mechanisms.” Id. at 6–7. The Petition’s entire “obvious to try” discussion is as follows: [A] POSITA would have found it obvious to try a one-piece airbag 10 with strip-shaped inflation units 12 in the EP’536- CN’180 airbag system because it would have been a selection from a finite number of identified predictable solutions (i.e., using one chamber with connected individual inflation units 12 versus multiple individual envelopes 20). 5 Petitioner also argues that dosing aids are “needed in order to make the disclosed device reusable.” Reh’g Req. 5–6. This is incorrect, as EP’536 conveys that the reusability of the device is a result of the gas generating agent condensing or recombining when temperatures fall. Ex. 1004 ¶¶ 139– 141. Even if it were true, however, it is unclear how it would support Petitioner’s argument. Pet. 16. As is evident, Petitioner did not identify a design need, market pressure, or other problem that would have been addressed by its identified “solutions,” and therefore we were not persuaded by this rationale. Dec. 19. Petitioner’s attempt to cure this deficiency in its Rehearing Request is tardy. We cannot misapprehend or overlook an assertion that Petitioner fails to make in the Petition. It is also insufficient. Petitioner does not provide any evidence of a known design need or market pressure to “simplify [EP’536’s] design” or reduce the number of “required inflation mechanism” it uses.” slip op. at 7

    § 103 obviousness
    Patents in suitUS 12,012,065
  • Pgr2025-00080Institution denied
    PTAB · Feb 3, 2026 · PGR2025-00080 · APJ John A Squires · PGR · Director review

    The Director denied institution of PGR2025-00080 after reviewing discretionary considerations.

    RulingsDirector review decision
    • Settled expectationsInstitution denied settled expectationsInstitution denied

      “NOTICE Pursuant to 35 U.S.C. § 314(a) and § 324(a), after review of discretionary considerations, institution of inter partes review or post-grant review is denied in the following proceedings: IPR2025-01510 IPR2026-00016 IPR2026-00035 IPR2025-01563 IPR2026-00019 IPR2026-00040 IPR2025-01596 IPR2026-00022 IPR2026-00041 IPR2025-01605 IPR2026-00023 IPR2026-00042 IPR2026-00008 IPR2026-00024 IPR2026-00043 IPR2026-00014 IPR2026-00031 PGR2025-00080 IPR2026-00015 IPR2026-00032” slip op. at 1

    Discretionary denial
    Patents in suitUS 12,268,265
  • Ipr2026-00015Institution denied
    PTAB · Feb 3, 2026 · IPR2026-00015 · APJ John A Squires · IPR · Director review

    The Director denied institution of IPR2026-00015 after review of discretionary considerations.

    RulingsDirector review decision
    • PTAB / AIA Trials › Discretionary denialInstitution denied discretionary otherDenied

      “NOTICE Pursuant to 35 U.S.C. § 314(a) and § 324(a), after review of discretionary considerations, institution of inter partes review or post-grant review is denied in the following proceedings: IPR2025-01510 IPR2026-00016 IPR2026-00035 IPR2025-01563 IPR2026-00019 IPR2026-00040 IPR2025-01596 IPR2026-00022 IPR2026-00041 IPR2025-01605 IPR2026-00023 IPR2026-00042 IPR2026-00008 IPR2026-00024 IPR2026-00043 IPR2026-00014 IPR2026-00031 PGR2025-00080 IPR2026-00015 IPR2026-00032” slip op. at 1

    Discretionary denial
    Patents in suitUS 11,138,997
  • Pgr2025-00075Institution denied
    PTAB · Feb 3, 2026 · PGR2025-00075 · APJ John A Squires · PGR · Institution

    The Director denied institution of PGR2025-00075 because the petitioner failed to show that at least one challenged claim was more likely than not unpatentable.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a) and § 324(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable. Accordingly, institution of inter partes review or post-grant review is denied in the following proceedings:” slip op. at 2

    None
    Patents in suitUS 12,142,371
  • Ipr2025-01407Institution denied
    PTAB · Feb 3, 2026 · IPR2025-01407 · APJ John A Squires · IPR · Institution

    The Director denied institution of IPR2025-01407 after finding the petitioner failed to show a reasonable likelihood of prevailing on at least one challenged claim.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a) and § 324(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable. Accordingly, institution of inter partes review or post-grant review is denied in the following proceedings: IPR2025-01407F1” slip op. at 2

    None
    Patents in suitUS 11,964,175
  • Ipr2025-01054Institution denied
    PTAB · Feb 3, 2026 · IPR2025-01054 · APJ John A Squires · IPR · Institution

    Institution of IPR2025-01054 was denied after the Director determined that the petitioner failed to show a reasonable likelihood of prevailing on at least one challenged claim.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a) and § 324(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable. Accordingly, institution of inter partes review or post-grant review is denied in the following proceedings:” slip op. at 2

    None
    Patents in suitUS 9,337,193
  • Ipr2025-01355Institution denied
    PTAB · Jan 16, 2026 · IPR2025-01355 · APJ John A Squires · IPR · Institution

    Institution of inter partes review in IPR2025-01355 was denied because the petitioner failed to show a reasonable likelihood of prevailing on at least one challenged claim.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition. Accordingly, institution of inter partes review is denied in the following proceedings: IPR2025-01185 IPR2025-01238 IPR2025-01355 IPR2025-01237 IPR2025-01353” slip op. at 2

    None
    Patents in suitUS 10,947,589
  • Ipr2025-01353Institution denied
    PTAB · Jan 16, 2026 · IPR2025-01353 · APJ John A Squires · IPR · Institution

    Institution of IPR2025-01353 was denied because the petitioner failed to show a reasonable likelihood of prevailing on at least one challenged claim.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied

      “Pursuant to 35 U.S.C. § 314(a), after review of the merits, the petitioner has failed to show a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition. Accordingly, institution of inter partes review is denied in the following proceedings: IPR2025-01185 IPR2025-01238 IPR2025-01355 IPR2025-01237 IPR2025-01353” slip op. at 2

    None
    Patents in suitUS 12,234,510

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