- Samsung Electronics Co., Ltd. v. Headwater Research LLCInstitution deniedPTAB · Sep 26, 2025 · IPR2025-00932 · APJ Kalyan K Deshpande · IPR · Director review
The Director granted Patent Owner’s discretionary-denial request and denied the petitions without instituting IPR under § 314(a), citing the parallel litigation and settled expectations.
RulingsDirector review decision- PTAB / AIA Trials › Discretionary denial › Fintiv (parallel litigation)Denied
“In particular, the projected final written decision due dates in the Board proceedings are in November and December 2026. DD Req. 13. The district court’s scheduled trial date is May 4, 2026, and the time-to-trial statistics suggest trial will begin in September 2026. DD Opp. 50. Additionally, there is insufficient evidence that the district court is likely to stay its proceeding even if the Board were to institute trial. Therefore, it is unlikely that a final written decision in these proceedings will issue before the district court trial occurs, resulting in significant duplication of effort, additional expense for the parties, and a risk of inconsistent decisions.” slip op. at 2
- Settled expectationsDenied
“In addition, the challenged patents have been in force for approximately seven years, creating settled expectations for Patent Owner, and Petitioner does not provide persuasive reasoning why an inter partes review is an appropriate use of Board resources. Dabico Airport Sols. Inc. v. AXA Power ApS, IPR2025-00408, Paper 21 at 2–3 (Director June 18, 2025).” slip op. at 2
- PTAB / AIA Trials › Discretionary denialInstitution denied settled expectationsDenied
“Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of 2 Citations are to papers in IPR2025-00932. The parties filed similar papers in IPR2025-00963. all of the evidence and arguments presented. Accordingly, the Petitions are denied under 35 U.S.C. § 314(a).” slip op. at 2
- Director reviewDirector review, deniedDenied
“Before KALYAN K. DESHPANDE,1 Acting Chief Administrative Patent Judge. DECISION Denying Institution of Inter Partes Review 1 Coke Morgan Stewart, Deputy Under Secretary of Commerce for Intellectual Property and Deputy Director of the United States Patent and Trademark Office, is recused and took no part in this decision. The Director has delegated his discretionary authority for this decision. See https://www.uspto.gov/sites/default/files/documents/dsco-delegation.pdf.” slip op. at 1
Discretionary denialPatents in suitUS 10,080,250 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Genghiscomm Holdings, LLCInstitution deniedPTAB · Sep 26, 2025 · IPR2025-00899 · APJ Kalyan K Deshpande · IPR · Director review
The Director granted Patent Owner’s discretionary denial request and denied institution under § 314(a) because the district court trial is likely to precede the final written decision.
RulingsDirector review decision- PTAB / AIA Trials › Discretionary denial › Fintiv (parallel litigation)Institution denied fintivDenied
“In particular, the projected final written decision due date for this case is November 27, 2026. The district court’s scheduled trial date is June 15, 2026, and the time-to-trial statistics suggest trial will begin by August 2026. DD Req. 5–6. As such, it is unlikely that a final written decision in this proceeding will issue before the district court trial occurs, resulting in significant duplication of effort, additional expense for the parties, and a risk of inconsistent decisions. Additionally, there is insufficient evidence that the district court is likely to stay its proceeding even if the Board were to institute trial. Id. at 4–5. Although the challenged patent has not been in force for a significant period of time (issued in 2022), this fact alone does not tip the balance against discretionary denial. Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petition is denied under 35 U.S.C. § 314(a).” slip op. at 2
Discretionary denialPatents in suitUS 11,431,386 - Lenovo (United States) Inc. / Motorola Mobility LLC v. Collision Communications, Inc.Institution deniedPTAB · Sep 19, 2025 · IPR2025-00927 · APJ Coke Morgan Stewart · IPR · Director review
The Director granted Patent Owner’s discretionary-denial request and denied institution under § 314(a), citing the parallel district court schedule, settled expectations, and a prior denied IPR.
RulingsDirector review decision- PTAB / AIA Trials › Discretionary denial › Fintiv (parallel litigation)Institution denied fintivDenied
“In particular, the projected final written decision due date in the Board proceeding is November 23, 2026. DD Req. 12. The district court’s scheduled trial date is January 5, 2026, and time-to-trial statistics show trial would begin in April 2026. Id. at 2. Therefore, it is unlikely that a final written decision in this proceeding will issue before the district court trial occurs, resulting in significant duplication of effort, additional expense for the parties, and a risk of inconsistent decisions.” slip op. at 2
- Settled expectationsInstitution denied settled expectationsDenied
“Additionally, the challenged patent has been in force for approximately 16 years, creating strong settled expectations for Patent Owner. Further, the challenged patent in this proceeding was the subject of a previous inter partes review, and the Board denied institution on the merits. Samsung Elecs. Am., Inc. v. Collision Comm’s, Inc., IPR2024- 01247, Paper 14 (PTAB Feb. 7, 2025). Repeat challenges raise concerns of road mapping and weigh against institution.” slip op. at 2
- Other 314aInstitution denied discretionary otherDenied
“Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petition is denied under 35 U.S.C. § 314(a).” slip op. at 2
Discretionary denialPatents in suitUS 7,593,492 - Toyota Motor Corp. v. Autoconnect Holdings LLCInstitution deniedPTAB · Sep 19, 2025 · IPR2025-00890 · APJ Coke Morgan Stewart · IPR · Director review
The Director granted Patent Owner’s discretionary denial requests and denied the petitions under § 314(a), with no trial instituted.
RulingsDirector review decision- Settled expectationsInstitution denied settled expectationsDenied
“Some considerations, however, favor discretionary denial. In particular, the challenged patents have been in force for approximately eleven and ten years, respectively, creating strong settled expectations for Patent Owner, and Petitioner does not provide persuasive reasoning why an inter partes review is an appropriate use of Board resources. Dabico Airport Sols. Inc. v. AXA Power ApS, IPR2025-00408, Paper 21 at 2–3 (Director June 18, 2025). Petitioner’s argument that Patent Owner does not have 1 Citations are to papers in IPR2025-00890. The parties filed similar papers in IPR2025-00891. strong settled expectations because “Patent Owner has not commercialized its purported inventions, nor has it done anything to improve the United States economy or public interest with its purported inventions,” without more, does not defeat Patent Owner’s strong settled expectations. DD Opp. 8. Additionally, Patent Owner provides evidence that it brought the challenged patents to Petitioner’s attention in 2023, which further supports discretionary denial. DD Req. 22; see Geotab Inc., v. Fractus, S.A., IPR2025-00928, Paper 11, 2–3 (Director Sept. 12, 2025).” slip op. at 2
- Other 314aInstitution denied discretionary otherDenied
“Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petitions are denied under 35 U.S.C. § 314(a). In consideration of the foregoing, it is: ORDERED that Patent Owner’s requests for discretionary denial are granted; and FURTHER ORDERED that the Petitions are denied, and no trial is instituted.” slip op. at 3
Discretionary denialPatents in suitUS 8,793,034 - Koito Manufacturing Co., Ltd. v. Longhorn Automotive Group LLCInstitution deniedPTAB · Sep 19, 2025 · IPR2025-00955 · APJ Coke Morgan Stewart · IPR · Director review
The Director granted Patent Owner’s discretionary-denial request and denied institution under § 314(a), citing parallel proceedings, settled expectations, and the holistic record.
RulingsDirector review decision- PTAB / AIA Trials › Discretionary denial › Fintiv (parallel litigation)Denied
“In particular, the projected final written decision due date in the Board proceeding is December 2, 2026. DD Req. 6. Although Patent Owner has not asserted the challenged patent against Petitioner in district court, the challenged patent is part of several district court proceedings involving other parties. Of these parallel proceedings, the earliest district court scheduled trial date is June 1, 2026. Id. As such, it is unlikely that a final written decision in this proceeding will issue before a district court trial occurs, resulting in significant duplication of effort, additional expense, and a risk of inconsistent decisions.” slip op. at 2
- Settled expectationsDenied
“Additionally, the challenged patent has been in force for more than eleven years, creating strong settled expectations for Patent Owner, and Petitioner does not provide persuasive reasoning why an inter partes review is an appropriate use of Board resources. Dabico Airport Solutions Inc. v. Axa Power Aps, IPR2025-00408, Paper 21 at 2–3 (Director June 18, 2025). Petitioner’s argument that Patent Owner does not have strong settled expectations because the challenged patent was not previously commercialized or asserted in the technology space of vehicle headlamps or headlights is unpersuasive. DD Opp. 4–5. Furthermore, Petitioner’s argument that it did not expect a patent claiming a “system for projecting a pattern of light” to be asserted in the technology space of vehicle headlamps is not persuasive. See Ex. 1001, col. 6, ll. 52–65 (claim 1).” slip op. at 2
- Other 314aDenied
“Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petition is denied under 35 U.S.C. § 314(a). In consideration of the foregoing, it is: ORDERED that Patent Owner’s request for discretionary denial is granted; and FURTHER ORDERED that the Petition is denied, and no trial is instituted.” slip op. at 3
Discretionary denialPatents in suitUS 8,810,803 - Alliance Laundry Systems, LLC v. Payrange LLCInstitution deniedPTAB · Sep 19, 2025 · IPR2025-00950 · APJ Coke Morgan Stewart · IPR · Director review
The Director granted Patent Owner’s discretionary-denial request and denied institution under § 314(a), citing the third petition, prior merits denials, road-mapping concerns, and settled expectations.
RulingsDirector review decision- PTAB / AIA Trials › Discretionary denial › General Plastic (serial petitions)Denied
“Other considerations, however, favor discretionary denial. In particular, this is the third petition involving the challenged patent. Both of the prior petitions were denied based on the merits. See Kiosoft Techs., LLC v. PayRange Inc., PGR2021-00084, Paper 12 (PTAB Dec. 16, 2021) (“Kiosoft PGR”); CSC ServiceWorks, Inc. v. PayRange Inc., IPR2023-01188 (PTAB Jan. 24, 2024). Petitioner states that it “relies on the same reference, Breitenbach, as a primary reference for both of its grounds of invalidity” that was used in the Kiosoft PGR. DD Opp. 4. Petitioner further states that “the present Petition addresses and cures any purported deficiencies with Breitenbach by relying on additional references Brown and Kaspar.” DD Opp. 36. Petitioner’s admission raises concerns of road mapping and weighs in favor of discretionary denial. See Amazon Web Servs., Inc. v. Croga Innovations, Ltd., IPR2025-00884, Paper 9, at 2 (Director Sept. 3, 2025).” slip op. at 2
- Settled expectationsDenied
“In addition, although the challenged patent has not been in force for a significant period of time (issued in 2021), Patent Owner presents evidence that it has licensed the challenged patent, which creates some settled expectations favoring Patent Owner. DD Req. 3. The considerations favoring discretionary denial outweigh those that counsel against it.” slip op. at 3
- Other 314aInstitution denied discretionary otherDenied
“example, the co-pending district court litigation was stayed on September 10, 2025. See Ex. 1026. As such, it is likely that a final written decision in this proceeding will issue before district court trial occurs.” slip op. at 2
Discretionary denialPatents in suitUS 10,891,608 - Volkswagen Group Of America, Inc. / Volkswagen AG et al. v. Longhorn Automotive Group LLCInstitution deniedPTAB · Sep 12, 2025 · IPR2025-00925 · APJ Coke Morgan Stewart · IPR · Director review
The Director denied institution of IPR2025-00925 under § 314(a), finding discretionary denial appropriate based on the totality of the evidence and arguments.
RulingsDirector review decision- Settled expectationsInstitution denied settled expectationsDenied
“Some considerations, however, favor discretionary denial. In particular, the challenged patent has been in force for thirteen years creating strong settled expectations for Patent Owner, and Petitioner does not provide persuasive reasoning why an inter partes review is an appropriate use of Board resources. Dabico Airport Sols. Inc. v. AXA Power ApS, IPR2025- 00408, Paper 21 at 2–3 (Director June 18, 2025). Further, Petitioner’s argument that the Examiner erred is unconvincing as it does not accurately characterize the prosecution history. See DD Opp. 2–7 (focusing on “removable storage”); Ex. 1003, 134 (interview summary discussing encrypted memory).” slip op. at 2
- Other 314aInstitution denied discretionary otherDenied
“Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petition is denied under 35 U.S.C. § 314(a).” slip op. at 3
- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied discretionary otherInstitution denied
“to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petition is denied under 35 U.S.C. § 314(a). In consideration of the foregoing, it is: ORDERED that Patent Owner’s request for discretionary denial is granted; and FURTHER ORDERED that the Petition is denied, and no trial is instituted.” slip op. at 3
Discretionary denialPatents in suitUS 8,085,192 - Oneplus Technology (Shenzhen) Co., Ltd. v. Pantech CorporationInstitution deniedPTAB · Sep 12, 2025 · IPR2025-00783 · APJ Coke Morgan Stewart · IPR · Director review
The Director denied institution in IPR2025-00783 under § 314(a), finding nine years of settled expectations and no persuasive reason to use Board resources for review.
RulingsDirector review decision- Settled expectationsInstitution denied settled expectationsDenied
“The patent challenged in IPR2025-00783 presents different circumstances. In particular, the challenged patent has been in force for nine years, creating strong settled expectations for Patent Owner, and Petitioner does not provide persuasive reasoning why an inter partes review is an appropriate use of Board resources. Dabico Airport Sols. Inc. v. AXA Power ApS, IPR2025-00408, Paper 21 at 2–3 (Director June 18, 2025). In the 1 Citations are to papers in IPR2025-00762. The parties filed similar papers in IPR2025-00783. absence of any such information, the Office is disinclined to disturb the strong settled expectations of Patent Owner.” slip op. at 2
- Director reviewDirector review, deniedDenied
“Although certain arguments are highlighted above, the determinations in this Decision are based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petition in IPR2025-00783 is denied under 35 U.S.C. § 314(a), and the Petition in IPR2025-00762 is referred to the Board to handle the case in the normal course, including by issuing a decision on institution addressing the merits and other non-discretionary considerations, as appropriate. In consideration of the foregoing, it is: ORDERED that Patent Owner’s request for discretionary denial in IPR2025-00783 is granted; FURTHER ORDERED that the Petition in IPR2025-00783 is denied, and no trial is instituted;” slip op. at 3
Discretionary denialPatents in suitUS 9,288,824 - Samsung Electronics Co. Ltd. / Samsung Electronics America, Inc. v. VB Assets, LLCInstitution deniedPTAB · Sep 12, 2025 · IPR2025-00869 · APJ Kalyan K Deshpande · IPR · Director review
The Director granted Patent Owner’s discretionary-denial requests and denied institution under § 314(a), citing settled expectations and prior adjudications.
RulingsDirector review decision- Settled expectationsInstitution denied settled expectationsDenied
“Other considerations, however, weigh in favor of discretionary denial. In particular, each of the challenged patents has been in force for more than ten years, creating strong settled expectations for Patent Owner. Additionally, the patents challenged in IPR2025-00866, IPR2025-00867,” slip op. at 2
- Other 314aInstitution denied discretionary otherDenied
“and IPR2025-00869 have all been subject to previous adjudications. The patents challenged in IPR2025-00866, IPR2025-00867, and IPR2025-00869 were involved in prior Board proceedings. In those proceedings, the Board denied institution of two petitions and entered a final written decision finding the challenged claims not unpatentable in the third proceeding. DD Req. 12; see also IPR2025-00867, Paper 8, 11–12; IPR2025-00869, Paper 8, 12. The patents challenged in IPR2025-00866 and IPR2025-00867 were also subject to a prior district court proceeding, in which the patents were found not invalid. DD Req. 12; IPR2025-00867, Paper 8, 12. It is not an efficient use of Board resources to further consider petitions challenging patents that have already been subject to challenges before the Office or patents that already have had validity adjudicated either at the Board or in another tribunal. Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petitions are denied under 35 U.S.C. § 314(a).” slip op. at 3
Discretionary denialPatents in suitUS 8,886,536 - Samsung Electronics Co. Ltd. / Samsung Electronics America, Inc. v. VB Assets, LLCInstitution deniedPTAB · Sep 12, 2025 · IPR2025-00866 · APJ Kalyan K Deshpande · IPR · Director review
The Director granted Patent Owner’s discretionary-denial requests and denied institution of IPR for the challenged patent under § 314(a).
RulingsDirector review decision- Settled expectationsInstitution denied settled expectationsDenied
“Other considerations, however, weigh in favor of discretionary denial. In particular, each of the challenged patents has been in force for more than ten years, creating strong settled expectations for Patent Owner. Additionally, the patents challenged in IPR2025-00866, IPR2025-00867,” slip op. at 2
- Other 314aInstitution denied discretionary otherDenied
“and IPR2025-00869 have all been subject to previous adjudications. The patents challenged in IPR2025-00866, IPR2025-00867, and IPR2025-00869 were involved in prior Board proceedings. In those proceedings, the Board denied institution of two petitions and entered a final written decision finding the challenged claims not unpatentable in the third proceeding. DD Req. 12; see also IPR2025-00867, Paper 8, 11–12; IPR2025-00869, Paper 8, 12. The patents challenged in IPR2025-00866 and IPR2025-00867 were also subject to a prior district court proceeding, in which the patents were found not invalid. DD Req. 12; IPR2025-00867, Paper 8, 12. It is not an efficient use of Board resources to further consider petitions challenging patents that have already been subject to challenges before the Office or patents that already have had validity adjudicated either at the Board or in another tribunal. Although certain arguments are highlighted above, the determination to exercise discretion to deny institution is based on a holistic assessment of all of the evidence and arguments presented. Accordingly, the Petitions are denied under 35 U.S.C. § 314(a).” slip op. at 3
Discretionary denialPatents in suitUS 8,073,681
Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.