- Alliance Laundry Systems, LLC v. Payrange LLCInstitution deniedPTAB · Oct 1, 2025 · IPR2025-00573 · APJ Meredith C Petravick · IPR · Institution
The Board denied institution because the Petition did not show a reasonable likelihood that claims 7 or 11 were unpatentable under the asserted obviousness grounds.
In the decision…prompted one of skill in the art “to combine . . . known elements in the fashion claimed by the patent at issue.” KSR, 550 U.S. at 418. A precise teaching directed to the specific subject matter of a challenged claim is not necessary to establish obviousness. Id. Rather, “any need or problem…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“Under 35 U.S.C. § 314(a), an inter partes review may not be instituted unless the information presented in the petition “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” After considering the Petition, the Preliminary Response, and the evidence of record, we determine the information presented fails to show a reasonable likelihood that Petitioner would prevail in establishing the unpatentability of at least one of the challenged claims of the ’772 patent. Accordingly, we do not institute an inter partes review of claims 7 and 11 of the ’772 patent on the grounds asserted in the Petition.” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner contends a person having ordinary skill in the art (“POSA”) pertaining to the ’772 patent “would have had an educational background of, engineering, computer engineering, computer science, or equivalent training, and approximately three years of experience with electronic payment systems, vending machine technologies, or distributed network systems.” Pet. 19–20; Ex. 1003 ¶¶ 20–26. “Lack of work experience can be remedied by additional education, and vice versa.” Pet. 20; Ex. 1003 ¶ 22. Patent Owner does not oppose Petitioner’s formulation of ordinary skill. See Prelim. Resp. generally. On this record, we adopt Petitioner’s assessment of the level of ordinary skill in the art as it is consistent with the ’772 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“In this inter partes review, we apply the same claim construction standard that would be used in a civil action under 35 U.S.C. § 282(b). 37 C.F.R. § 42.100(b). In applying this standard, we generally give claim terms their ordinary and customary meaning as would be understood by a person of ordinary skill in the art at the time of the invention and in the context of the entire patent disclosure. See id.; Phillips v. AWH Corp., 415 F.3d 1303, 1312–14 (Fed. Cir. 2005) (en banc). We do not need to construe any terms expressly to determine whether or not to institute a trial. See Realtime Data LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 10
- Obviousness (§103) › Motivation to combine / reasonable expectation of successNot reached
Claim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,481,772 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. KP Innovations 2, LLCInstitution deniedPTAB · May 12, 2025 · IPR2025-00101 · APJ Jameson Lee · IPR · Institution
The Board denied institution of review of claims 18–21, finding no reasonable likelihood on three grounds and declining institution in view of the limited potential reach of the remaining ground.
In the decision…fifth embodiment already includes a video conferencing camera facing the user, mounted in the hinge connecting case bodies 1 and 2. In light of that teaching, there is little reason to add a camera to the inward facing side of Nagasawa’s case body 1. For the foregoing reasons, Petitioner has not…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“Regarding the alleged anticipation by Okaya, Petitioner has not adequately shown that Okaya discloses that the audio and video outputs of carousel 10 connect to a communication network without the intervening use of a computer or video conferencing system to which the carousel is connected. Okaya specifically describes that “the multimedia carousel 10 includes several input and output terminals for integrating with a multimedia computer or video conferencing system.” Ex. 1006, 3:1–4. The specific scenario described in Okaya, in column 3, lines 43 to 61, also has carousel 10 connected to a notebook PC. Thus, Petitioner’s arguments based on carousel 10 itself as the device of limitation [18a] is inadequate. See also” slip op. at 13
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentable
“For reasons discussed below, we find Petitioner’s reasoning to be insufficient for one of ordinary skill in the art to add two cameras to Nagasawa’s case body 1, one on each side of case body 1. Petitioner does not adequately address the issue of sufficient spacing on Nagasawa’s case body 1, which includes two back-to-back mounted displays 4 and 8 (Figure 1A), to include two additional cameras, one facing inward and the other facing outward, particularly as one side of case body 1 is used for gaming (Fig. 1B, Ex. 1007, 3:53–65). In Nagasawa’s fifth embodiment, which includes a camera for video conferencing, the camera is placed in the hinge connecting case bodies 1 and 2, and not within case body 1. That is an indication that there is not enough room in Nagasawa’s case body 1 to incorporate a camera, much less two cameras as Petitioner has proposed to meet limitations [18c] and [18d]. Nagasawa’s Figure 12B is reproduced below: Figure 12B is a front view of a fifth embodiment of Nagasawa’s foldable phone in the unfolded position. Ex. 1007, 3:24–26. Nagasawa describes: “Video conference display may be provided where the photo sticker 51 is to be affixed in order to provide folding portable apparatus equipped with a small-sized TV camera 53 at the hinge.” Id. at 7:36–39. Nagasawa’s design already dictates where a camera would be mounted, and omits discussion of any other locations of that camera, much less a placement of it on the phone case body. Id.” slip op. at 23
- Expert testimonyPatent owner expert creditedDecided for patent owner
“Additionally, Dr. Theogarajan testifies: “A person using [Nagasawa’s] pocket game would cover any camera placed on the outer surface of the first case body. Any camera placed in such a position would be abused with dirt and oil from a game player’s hand.” Ex. 2001 ¶ 145. We credit the testimony. It further undermines Petitioner’s proposed addition of two cameras to Nagasawa’s case body 1. Also, Nagasawa’s fifth embodiment already includes a video conferencing camera facing the user, mounted in the hinge connecting case bodies 1 and 2. In light of that teaching, there is little reason to add a camera to the inward facing side of Nagasawa’s case body 1.” slip op. at 24
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“Petitioner asserts: “[T]he Board need not construe any term because the prior art invalidates the claims under any plausible construction.” Pet. 12. Petitioner has not proposed an express construction for any claim term. Patent Owner asserts that “[t]he term ‘receive and transmit information’ [in claim 18] means real-time or near real-time audio and visual information.” Prelim. Resp. 15–16. Patent Owner further argues that “Petitioner accepts Patent Owner’s construction because the construction is a plausible construction, and Petitioner stated that they believe their art invalidates the claims under any plausible constructions.” Id. at 16. For purposes of this Decision, however, we need not decide whether to adopt Patent Owner’s proposed construction. C.” slip op. at 8
Claim construction§ 103 obviousnessDiscretionary denialcites PhillipsPatents in suitUS 10,499,168 - Deere & Company v. David’S Dozer V-Loc System, Inc.Institution deniedPTAB · Mar 18, 2025 · IPR2024-01442 · APJ Robert J Silverman · IPR · Institution
The Board denied institution because Petitioner did not show a reasonable likelihood of proving claims 1–4 unpatentable under any asserted obviousness ground.
In the decision…Cir. 1994) (citing In re Samour, 571 F.2d 559, 562 (CCPA 1978)). The Supreme Court has explained that an obviousness determination may consider, the teachings of multiple prior art references, the knowledge and capabilities of persons having ordinary skill in the art (at the relevant time), as well…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsDenied
“review. See 35 U.S.C. § 314; 37 C.F.R. § 42.4(a). Under 35 U.S.C. § 314(a), we may not authorize an inter partes review unless the information in the Petition and the Preliminary Response (including any other authorized submissions) “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.”” slip op. at 8
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Patent Owner’s proposal for the level of ordinary skill in the art differs from that of Petitioner, primarily because Patent Owner contends that such a person of ordinary skill would have a certain degree of experience relating specifically to skid steers, or similar machinery, and their hydraulic systems. See Prelim. Resp. 8–10 (citing Ex. 2001 ¶ 31). Insofar as we understand the significance of Patent Owner’s concerns about the differences between the parties’ proposals, these differences do not bear upon the issues addressed herein. Accordingly, for the purposes of the present Decision, we adopt Petitioner’s proposed definition of the relevant level of ordinary skill in the art. Further, with regard to the issues addressed in this Decision, Petitioner’s proposed description of the level of ordinary skill in the art appears to be consistent with the level of skill indicated by the ’300 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 11
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed patent owner constructionDecided for patent owner
“We agree with Patent Owner. Petitioner argues that “Patent Owner made the deliberate choice to claim broadly,” eschewing “structural limitations that would have expressly or implicitly required the hydraulic of Element [1.4] to differ from the hydraulic of Element [1.5].” Reply 7. Further, Petitioner argues that “Patent Owner chose to generically recite ‘a hydraulic’ in each of Elements [1.4] and [1.5] without distinguishing labels, identifiers, or qualifiers.” Id. To the contrary, the two recited “hydraulic[s]” are distinguished by the language surrounding and modifying each instance in the method of claim 1. Indeed, the recitations of distinct operations performed by each “hydraulic,” in the claimed method, further support the understanding these are distinct and different structures. Additionally, as Patent Owner contends (see Prelim. Resp. 16), each instance of “hydraulic” is introduced with the indefinite article “a” — a signal that the two instances of “a hydraulic” do not refer to the same structure. See Becton, Dickinson and Co. v. Tyco Healthcare Group, LP, 616 F.3d 1249, 1254 (Fed. Cir. 2010) (“Where a claim lists elements separately, ‘the clear implication of the claim language’ is that those elements are ‘distinct components’ of the patented invention.”) (quoting Gaus v. Conair Corp., 363 F.3d 1284, 1288 (Fed. Cir. 2004)); see also CAE Screenplates, Inc. v. Heinrich Fiedler GmbH & Co., 224 F.3d 1308, 1317 (Fed. Cir. 2000) (“In the absence of any evidence to the contrary, we must presume that the use of . . . different terms in the claims connotes different meanings.”); Engel Indus., Inc. v. Lockformer Co., 96 F.3d 1398, 1404–05 (Fed. Cir. 1996) (concluding that where a claim provides for two separate elements, a “second portion” and a “return portion,” these two elements “logically cannot be one and the same”).” slip op. at 13
- Obviousness (§103) › Motivation to combine / reasonable expectation of success › Teaching awayTeaching away foundNot shown unpatentableNot shown unpatentable
“As Patent Owner argues, Petitioner’s proposed combination of Funk and Lewis “would interfere with the intended operation of the Funk control system to move the lift arms up and down in response to inter alia changes in the height signal.” Prelim. Resp. 20. This scenario is similar to that in Tec Air, 192 F.3d at 1356, which involved a claimed injection-molding technique that used screw-threaded adjustable plugs accessed from the inner, cavity-facing, side of the mold. The proposed combination included a prior art reference disclosing adjustment members accessed from the opposite, outer, side of the mold, and having a non-threaded smooth tip that extended through the mold and into the cavity. Id. at 1360. The Federal Circuit held that the prior art reference was properly determined to teach away from the claimed invention, because “no screw driver would be able to turn the smooth-headed screws from the cavity-side of the mold,” hence the proposed “combination would be inoperable for its intended purpose.” Id. Likewise, the proposed combination in the present matter teaches away from the subject matter of claim 1, because it would “immobilize [Funk’s] main arm,” and its associated hydraulic cylinder 18, “leaving just ‘one’ of Funk’s two adjustment mechanisms — blade tilt — available for grade control” (Pet. 10), thereby decreasing the system’s accuracy (see Ex. 2001 ¶¶ 113– 14) and negating the very technique that Funk relies upon to achieve its stated goal. See Ex. 1004 ¶ 7 (“[O]ne object of the present invention is to provide an automatic leveling control system that is sufficiently accurate for preparing the ground prior to the construction of concrete floors and foundations.”)” slip op. at 28
Claim construction§ 103 obviousnessDiscretionary denialcites Phillips · Markman · KSR · GrahamPatents in suitUS 10,533,300 - PTAB · Dec 12, 2024 · IPR2024-00993 · APJ James A Tartal · IPR · Institution
The Board denied institution because Petitioner did not show a reasonable likelihood that any challenged claim was obvious over the asserted combinations.
In the decision…needs, failure of others, etc.” Id. at 17–18; KSR, 550 U.S. at 407. “Whether an ordinarily skilled artisan would have been motivated to modify the teachings of a reference is a question of fact.” WBIP, LLC v. Kohler Co., 829 F.3d 1317, 1327 (Fed. Cir. 2016) (citations omitted). “[W]here a party…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“review. 35 U.S.C. § 314(b) (2018); 37 C.F.R. § 42.4(a) (2023). An inter partes review may not be instituted “unless . . . the information presented in the petition . . . shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” 35 U.S.C. § 314(a). Upon consideration of the Petition, the Preliminary Response, the Reply, the Sur-reply, and the evidence of record, we conclude that the information does not demonstrate a reasonable likelihood that Petitioner would prevail in showing the unpatentability of at least one of the Challenged Claims. Accordingly, we deny institution of inter partes review.” slip op. at 2
- Skill levelOther
“Petitioner contends a person of ordinary skill in the art at the time of the invention “would have had a Bachelor’s degree or comparable technical degree in Industrial Design or Mechanical Engineering or equivalent work experience, and at least one year’s worth of experience in research, design and/or development related to appliances for moving air such as hair dryers (or other comparable industrial design),” and that “[a]dditional education could substitute for experience, and vice versa.” Pet. 17–18 (citing Ex. 1003 ¶¶ 17–19. At this stage of the proceeding, Patent Owner does not contest Petitioner’s proposed level of ordinary skill in the art. Prelim. Resp. 27–28. We find, for purposes of this Decision, that the ’979 patent and the cited prior art references reflect the appropriate level of skill at the time of the claimed invention and that the level of appropriate skill reflected in these references and in the ’979 patent is consistent with the definition of a person of ordinary skill in the art proposed by Petitioner. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 15
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner proposes no express construction and contends that the Petition is based on Patent Owner’s position in district court that no construction is necessary. Pet. 6–7 (citing Ex. 1013). Patent Owner proposes no express construction at this stage of the proceeding, and states that “the claim terms can be afforded their plain and ordinary meaning.” Prelim. Resp. 28. Only terms that are in controversy need to be construed, and these need be construed only to the extent necessary to resolve the controversy. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’”) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)). In the absence of any dispute over the construction of any claim term, we find no express construction necessary for purposes of this Decision.” slip op. at 16
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentableNot shown unpatentable
“3. Reasons Supporting the Combination of Saito and Lindsey Petitioner also fails to show sufficiently a reason for the asserted combination of Saito and Lindsey. See Pet. 22–29. Petitioner argues, for example, that a person of ordinary skill in the art “would have been motivated to combine Saito’s brush attachment with Lindsey’s teaching of an array of vanes, disposed in a turbinate arrangement, to generate a spinning airflow to provide increased lift and volume to the hair.” Pet. 26 (citing Ex. 1003 ¶¶ 90–94). According to Petitioner, “incorporation of vanes, as taught by Lindsey, would have improved Saito’s hair styling attachment by changing the air flow paths from an outwardly radial direction to transverse or perpendicular (i.e., tangential) to create a spinning/rotational flow.” Id. (citing Ex. 1003 ¶ 90). Petitioner, however, fails to show sufficiently that Lindsey’s attachment generates a “spinning/rotational flow.” In fact, Petitioner notes that Lindsey, itself, describes the discharge of air as being in a “spinning, turbulent manner” which provides “additional lift and volume to hair.” Pet. 27 (quoting Ex. 1005, 10:28–33); see also Ex. 1005, 9:47–64 (stating that the “turbinate arrangement and the features of the vanes and their disposition provide flow paths of discharged air having continually varying and spiraling radii about the axis of air flow” and that “the discharged hot air is spun out from the central portion of the vanes in a turbulent manner”). Additionally, Patent Owner argues, and we agree, that Petitioner does not provide any reason for “the six additional unacknowledged modifications” to the vanes of Lindsey employed in Petitioner’s asserted combination as depicted in Petitioner’s model attachment. Prelim. motivation for those changes alone is reason enough to deny institution.” Id. at 59. Indeed, Petitioner neither acknowledges, for example, that its model attachment eliminated the prongs and holes of the vanes of Lindsey nor offers any sufficient reason why a person of ordinary skill in the art would have done so. Absent from the Petition is any sufficient explanation why a person of ordinary skill in the art would have only chosen attachment features from Saito and Lindsey that correspond to claimed elements of the ’979 patent, while disregarding all attachment features taught by Saito and Lindsey that are inconsistent with claimed elements of the ’979 patent. In sum, we have considered all of the arguments advanced by Petitioner in support of its asserted combination and determine Petitioner has not sufficiently shown a reasonable likelihood of prevailing in its assertion that a person of ordinary skill would have had reason to combine the asserted references in the manner set forth in the Petition by Petitioner.11” slip op. at 32
Claim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,044,979 - Voltage, LLC v. Shoals Technologies Group, LLCInstitution deniedPTAB · Nov 22, 2024 · IPR2024-00877 · APJ Avelyn M Ross · IPR · Institution
The Board denied institution on all challenged claims because Petitioner did not show a reasonable likelihood that any challenged claim would have been obvious over the asserted combinations.
In the decision…provide easy-to-follow instructions for assembly.” Id. Patent Owner, at this time, does not challenge many of Petitioner’s allegations regarding the teachings of Fan, Ba, and Yen. See generally Prelim. Resp. Instead, Patent Owner focuses its argument on whether Petitioner has shown a reason to…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“review. 35 U.S.C. § 314 (2018); 37 C.F.R. § 42.4(a) (2023). The standard for instituting an inter partes review is set forth in 35 U.S.C. § 314(a), which provides that an inter partes review may not be instituted “unless the Director determines . . . there is a reasonable likelihood that the petitioner would prevail with respect to at least [one] of the claims challenged in the petition.”” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“The parties dispute whether a person of ordinary skill in the art must have experience with photovoltaic (solar) systems or whether such experience may be in the broader field of electrical wiring and connectors. In light of the record before us, and for purposes of this Decision, we adopt Petitioner’s proposal regarding the level of ordinary skill in the art. On this preliminary record, we determine that the definition offered by Petitioner comports with the qualifications a person would have needed to understand the ’739 patent and the prior art. But, for purposes of this institution decision, and on the present record, we observe that the adoption of either party’s proposal regarding requisite work experience would not change our analysis or conclusions.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Not reached
“The Board “need only construe terms that are in controversy, and only to the extent necessary to resolve the controversy.” Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (internal citation omitted). Because no claim construction is required in order to address the issues presented in this proceeding, we need not address claim construction for purposes of institution.” slip op. at 10
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentableNot shown unpatentable
“On this record, we are not persuaded Petitioner has adequately shown a reason to combine Fan and Ba. Petitioner argues that the ordinarily skilled artisan would have modified the in-line fuse assembly of Fan to include the plug and connector of Ba that physically integrates with the fuse in order to eliminate extra wire pieces. Pet. 14. But the details of Petitioner’s combination end there. Eliminating extra wire pieces may be advantageous and might be a reason for a person of ordinary skill in the art to modify the teachings of Fan. However neither Petitioner nor its declarant, Dr. Kenny, identify what wires are eliminated or explain why the elimination of wires in this case is advantageous. Furthermore, Petitioner does not direct our attention to any teaching in Ba that discusses the elimination of wires as a benefit to its structure. Thus, even if an ordinarily skilled artisan could have made the combination, Petitioner failed to sufficiently explain why an ordinary artisan would have been motivated to do so. See, e.g., Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed. Cir. 2015) (“[O]bviousness concerns whether a skilled artisan not only could have made but would have been motivated to make the combinations or modifications of prior art to arrive at the claimed invention.”) (citing InTouch Techs., Inc. v. VGO Commc’ns, Inc., 751 F.3d 1327, 1352 (Fed. Cir. 2014)).” slip op. at 18
Claim construction§ 103 obviousnessDiscretionary denialcites Phillips · KSR · GrahamPatents in suitUS 10,553,739 - Uber Technologies, Inc. v. Enovsys LLCInstitution deniedPTAB · Nov 22, 2024 · IPR2024-00825 · APJ Andrew L Nalven · IPR · Institution
The Board denied institution because the petition did not show a reasonable likelihood of proving any challenged claim unpatentable under the asserted obviousness grounds.
In the decision…distance or boundary as the requisite structure to perform the recited function. Id. More specifically, Petitioner refers to the ’726 patent’s teaching of a “page,” “poll,” or “query” as relaying mobile information to and from the portable mobile remote units of the network. Id. (citing Ex.…
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), an inter partes review may not be instituted “unless . . . there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons that follow, we determine that Petitioner has not demonstrated a reasonable likelihood of prevailing in demonstrating the unpatentability of at least one of the challenged claims. Accordingly, we decline to institute an inter partes review.” slip op. at 2
- Claim Construction › Functional claiming / §112(f) means-plus-function › Corresponding structure / algorithm (indefinite if none)Term construed patent owner constructionDecided for patent owner
“Step 1 of Figure 7 begins by obtaining the geographic information of the area to search for possible remote targets. Id. at 8:57–59. In step 2, the next geographic region where a possible search for a PRU is estimated. Id. at 8:64–66. In step 3, a page is sent out to that geographic region for remote units in the region to reveal their location. Id. at 9:2–4. In steps 4 and 5, if remote units are identified in the paged area, that information is forwarded to the network and the process continues to step 7 where the process is aborted. Id. at 9:4–6. Step 6 is performed if no units are identified in the paged area. Id. at 9:6–9. There, a check is done to establish if there are any remaining cells or grids higher up in the chain to be searched, and if so, the process returns to step 2 to search additional geographic areas. Id. at 9:9–12. The iterative process described in Figure 7 is consistent with Patent Owner’s proposed construction requiring forwarding a notification to only one or more PRUs currently located in a specific geographic boundary. Ex. 2001 ¶ 55; see also Ex. 1001, 8:32–54 (describing a grid search technique that may be implemented by the process of Figure 7).” slip op. at 13
- Skill levelSkill level petitioner adoptedDecided for petitioner
“(“POSITA”) would have had “a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and at least two years of experience in the research, design, development, and/or testing of GPS and related location tracking techniques, or the equivalent.” Pet. 8 (citing Ex. 1002 ¶¶ 28–30). Patent Owner does not dispute Petitioner’s proffered definition as to the level of ordinary skill in the art. Prelim. Resp. 6. For purposes of this Decision, we adopt Petitioner’s assessment, which is consistent with the level of skill reflected in the Specification and asserted prior art.” slip op. at 16
- Expert testimonyPatent owner expert creditedDecided for patent owner
“We are further not persuaded by Petitioner’s argument that forwarding notifications to the PRUs only within a specified geographic region renders element 12[D]’s step of verifying whether the PRUs exists within said region unnecessary. Pet. 35 n.8. Rather, we credit Mr. McAlexander who testifies that forwarding notifications to individually pollable geographic boundaries “does not obviate the need for the PRU to identify that the notification has been received or verify its location within the individual geographic boundary before responding.” Ex. 2001 ¶ 155.” slip op. at 15
Claim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 7,199,726 - PTAB · Oct 25, 2024 · IPR2024-00980 · APJ Lisa A Murray · IPR · Institution
The Board denied institution on all challenged claims because Petitioner did not show a reasonable likelihood of proving them obvious over Grinspun and Graphicxtras.
In the decision…different one based on design incentives or other market forces if the variations are predictable to one of ordinary skill in the art; and, (G) some teaching, suggestion, or motivation in the prior art that would have led one of ordinary skill to modify the prior art reference or to combine prior…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“review. See 35 U.S.C. § 314; 37 C.F.R. § 42.4(a) (2024) (“The Board institutes the trial on behalf of the Director.”). Section 314(a) of Title 35 of the United States Code provides that an inter partes review may not be instituted “unless . . . the information presented in the petition . . . shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” Upon consideration of the evidence and arguments in the Petition (including its supporting testimonial evidence) as well as the evidence and arguments in the Preliminary Response, we determine that the information presented does not show a reasonable likelihood that Petitioner would prevail with respect to at least one of the challenged claims of the ’448 Patent. We thus determine not to institute an inter partes review of any of the challenged claims on any of the grounds alleged in the Petition. A. Real Parties in Interest” slip op. at 2
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“The parties agree that no claim terms need to be construed for the purposes of a Decision on Institution, but disagree as to whether the preamble of method claim 1 is limiting. Petitioner argues that it is not, while Patent Owner argues that statements of intended purpose in the preamble to a method claim are generally construed as limiting. Pet. 31–32 (citing Arctic Cat Inc. v. GEP Power Prods., 919 F.3d 1320, 1328–1330 (Fed. Cir. 2019)); Prelim. Resp. 19 (quoting Eli Lilly and Co. v. Teva Pharma. Int’l GmbH, 8 F.4th 1331, 1340 (Fed Cir. 2021)). We determine that we do not need to resolve this potential claim construction dispute between the parties. See, e.g., Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’”) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)). For the reasons discussed below, even if we adopt Petitioner’s position that the preamble of claim 1 is not limiting, Petitioner still has not established a reasonable likelihood of success regarding its challenge to claim 1.” slip op. at 9
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner contends that one of ordinary skill in the art would have had “a minimum of a bachelor’s degree in an engineering, computer science, graphic design, or a related field plus 2–3 years of work and/or research experience in the field of computer aided design (CAD) software.” Pet. 12. Petitioner asserts that “[g]raduate education could substitute for professional experience, or significant experience in the field could substitute for formal education.” Id. Patent Owner largely agrees with Petitioner’s proposal, but argues that the relevant experience would have had to have been in “creating computer programs for virtual or digital clothing design” because general CAD software is not suitable for the purposes of virtual clothing design. Prelim. Resp. 18–19. We need not determine which definition is more consistent with the ’448 Patent and the asserted prior art. We have applied Petitioner’s definition in our analysis below. We determine that even under Petitioner’s definition of the level of ordinary skill in the art, Petitioner has not established a reasonable likelihood of success with respect to any of the claims challenged in the Petition, for the reasons discussed below. C. Claim Construction” slip op. at 8
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable
“First, Petitioner has not sufficiently shown that either Grinspun or Graphicxtras teach taking measurements “of” a two-dimensional pattern, as described in the preamble of claim 1. See Prelim. Resp. 20–23. Grinspun provides a 2D pattern in its Design Window 110, but does not measure any part of the 2D pattern. Id. at 20; Ex. 1004 at 17, 37–38, Fig. 1; see also Ex. 2001 ¶¶ 76–77 (Govindaraj Decl.). Graphicxtras teaches taking horizontal or vertical measurements between bounding boxes, but does not measure the distance between the actual outlines of the pattern pieces. Ex. 1005 (Graphicxtras); see Ex. 2001 ¶¶ 79–81. Even if the preamble is not considered to be limiting, the fact remains that neither reference discloses measuring a distance within a pattern piece, which is required by the claim language “determining a length of a line segment using the points . . . responsive to determining that the points are located in different pattern pieces[.]” Ex. 1001 at 18:3–4 (emphasis added); see Ex. 2001 ¶¶ 84–85. Second, Petitioner has not shown that either reference, alone or in combination, can determine whether two points are on the same pattern piece or different pattern pieces by affirmatively examining “attributes of areas” in which the points are located. Prelim. Resp. 27–29 (citing Ex. 2001 ¶¶ 87–90). The ’448 Specification indicates that a “measuring apparatus may determine that areas to which the two points A and B belong correspond to different pattern pieces based on the data structure corresponding to each of the two points A and B.” Ex. 1001 at 7:25–40. The data structure corresponding to each of the points may store information corresponding to each of the points in the form of a linked list, a tree, or a table, for example. The information corresponding to each of the points may include, for example, identification information of a pattern piece in which each of the points is positioned, identification of a line in a pattern piece in which each of the points is positioned, a coordinate of a point on a line of a pattern piece, and the like. Id. at 6:63–7:4. This is reflected in claim 1, which contains the limitation “determining a length of a line segment using the points based on the determined attributes of the areas, the determined length of the line segment changed to account for separation between the pattern pieces responsive to determining that the points are located in different pattern pieces[.]” Ex. 1001 at 17:66–18:4. The Grinspun-Graphicxtras combination does not do this. Rather, in the proposed combination the two points A and B are always on the edges of two different pattern pieces, and there is no disclosure of a set of data structures that would enable the proposed software to determine the location of the points in relation to the 2D pattern pieces depicted. Prelim. Resp. 27–29 (citing Ex. 2001 ¶ 90); see Pet. 35 (annotating Figure 1 of Ex. 1004). Third, because the line segment in the proposed combination is always between the edges of two different pattern pieces, the combination does not determine the “length of a line segment using the points based on the determined attributes of the areas” associated with the two points. Prelim. Resp. 41–42 (citing Ex. 2001 ¶¶ 91–93); Ex. 1001 at 17:62–65 (emphasis added); see also Pet. 40, 42, 44 (further annotating Figure 1 of Ex. 1004). Fourth, Petitioner misinterprets the claim language “the determined length of the line segment changed to account for separation between the pattern pieces” and does not does not even address the remainder of that claim element, “responsive to determining that the points are located in different pattern pieces.” See Ex. 1001 at 18:1–4 (emphasis added). This language does not mean that the user manually changes the length of the line segment by moving the pattern pieces. See Pet. 40–44. It means that the portion of the line segment that is in the empty space between the pattern pieces is subtracted, as shown in Figure 4 of the ’448 Patent, in order to determine the measurement of a portion of the 3D clothing to be created from the 2D pattern. Prelim. Resp. 40–41 (citing Ex. 2001 ¶¶ 94–95). We agree with and adopt the explanation of Patent Owner’s expert declarant, Dr. Govindaraj that: [T]he ’448 teaches repeatedly and the claims require that the patterns are fixed relative to one another, that the selected points are fixed, and that the line segments are fixed. The entire purpose of the claimed invention is to measure the length of a line segment in response to determining that the points are located in different pattern pieces, and then accounting for the “white space” or “separation between” the two patterns. Ex. 2001 ¶ 95. Patent Owner raises additional arguments as to why claim 1 would not” slip op. at 18
Claim construction§ 103 obviousnesscites Phillips · GrahamPatents in suitUS 11,222,448 - Intelligent Wellhead Systems, Inc. v. Downing Wellhead Equipment, LLCInstitution deniedPTAB · Sep 12, 2024 · IPR2024-00583 · APJ Benjamin D M Wood · IPR · Institution
The Board denied institution on all grounds because Petitioner did not show a reasonable likelihood of prevailing on any challenged claim.
In the decision…added). Ciezobka does not, however, teach such a comparison. Assuming that the initial flow rate can be considered a “threshold,” Ciezobka’s teaching of the existence of an initial flow rate followed by the existence of a lower pulse 15 IPR2024-00583 Patent 11,401,779 B2 flow rate does not…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“II. ANALYSIS A. Legal Standards Used in the Merits Analysis “In an IPR, the petitioner has the burden from the onset to show with particularity why the patent it challenges is unpatentable.” Harmonic Inc. v. Avid Tech., Inc., 815 F.3d 1356, 1363 (Fed. Cir. 2016) (citing 35 U.S.C. § 312(a)(3) (requiring inter partes review petitions to identify “with particularity . . . the evidence that supports the grounds for the challenge to each claim”)); Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015) (discussing the burden of proof in inter partes review).” slip op. at 7
- Skill levelSkill level petitioner adoptedDecided for petitioner
“B. Level of Ordinary Skill in the Art Petitioner contends that, for the ’779 patent, one of ordinary skill in the art “would have had an engineering degree and two or more years’ wellrelated operations experience, or equivalent education/experience.” Pet. 8. Patent Owner does not offer an alternative definition, but its Declarant, Mr. Hughett, submits that one of ordinary skill in the art would have had “a degree in petroleum or mining engineering, mechanical engineering, or a comparable discipline, and at least two years of experience in oil and gas extraction, or an equivalent combination of education and experience.” Ex. 2006 ¶ 17. On the record, we do not discern a meaningful difference between Petitioner’s and Mr. Hughett’s proposed definitions, and therefore adopt Petitioner’s definition for purposes of this Decision. We also presume that the cited prior-art references reflect the level of ordinary skill at the time of the invention. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (explaining the level of ordinary skill in the art may be evidenced by the cited references themselves).” slip op. at 8
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner
“The Specification does not suggest a particular definition of threshold, and neither party suggests that it is a term of art in the relevant field. Therefore, we consult a general dictionary for guidance. See Comaper Corp. v. Antec, Inc., 596 F.3d 1343, 1348 (Fed. Cir. 2010) (If “the specification does not assign or suggest a particular definition [of a claim term], in determining the ordinary and customary meaning of the claim term as viewed by a person of ordinary skill in the art, it is appropriate to consult a general dictionary definition of the word for guidance.”). Because Merriam-Webster’s online dictionary, Merriam-Webster.com, provides several definitions for threshold, we refer to the intrinsic record “to identify which of the different possible dictionary meanings is most consistent with the use of the words by the inventor.” Brookhill-Wilk 1, LLC v. Intuitive Surgical, Inc., 334 F.3d 1294, 1300 (Fed. Cir. 2003). Based on the context in which threshold is used in claims 1 and 8, we consider the most relevant definition to be “a level, point, or value above which something is true or will take place and below which it is not or will not.” Merriam- Webster.com/dictionary/threshold (accessed July 30, 2024). The claim context also indicates that threshold encompasses the opposite situation, i.e., the threshold may be a value below which something is true or will take place and above with it is not true or will not take place. Thus, a flow-rate value and time value are “thresholds” when there is an action that will or will not take place (or something is or is not true) depending on whether those values are met. The Specification identifies one particular action that occurs when these thresholds are met: performance of a CP swap from hydraulically fracturing the n1 well (i.e., a first well) to hydraulically fracturing the n1+1 well (i.e., a second well). Ex. 1001, 13:28–52, Figs. 1B, 12. To perform a CP swap, according to the Specification, zipper valves for the n1+1 well are opened while fluid is being pumped to the n1 well, allowing hydraulic fracturing fluid to flow to both wells, after which zipper valves for the n1 well are closed. Id. at 14:14–38, Figs. 15, 16A, 16B, 16C. This procedure is precisely what claims 1 and 8 recite. In addition to requiring “determining that the flow rate is below a flow-rate threshold . . . for a threshold amount of time,” claims 1 and 8 recite, e.g., “(c) during pumping of the fluid into the first well via the first valve, opening a second valve associated with a second well,” and “(e) during pumping of the fluid into the second well via the second valve, closing the first valve associated with the first well.” Ex. 1001, claims 1, 8. Thus, in the context of these claims, a flow-rate threshold and threshold amount of time would be flow-rate and time values that determine whether or not a second valve associated with a second well is opened during pumping of fluid into the first well via the first valve.” slip op. at 9
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable
“We are not persuaded that Ciezobka teaches or suggests limitation [1.3]. First, we agree with Patent Owner that this limitation necessarily requires comparing the measured flow rate to a threshold. Petitioner also appears to agree that such a comparison is necessary to perform limitation [1.3]. See Pet. 15 (“Ciezobka discloses determining the flowrate of the fluid and comparing the determined flowrate to certain thresholds . . . , and therefore discloses determining that the flow rate of the fluid being pumped into the first well is below a flowrate threshold.”) (emphasis added). Ciezobka does not, however, teach such a comparison. Assuming that the initial flow rate can be considered a “threshold,” Ciezobka’s teaching of the existence of an initial flow rate followed by the existence of a lower pulse flow rate does not constitute a teaching of a comparison of the two flow rates. Second, Petitioner has not established that the “initial flow rate” is a “threshold.” As discussed above, we construe “flow rate threshold” in the context of claim 1 to mean a flow rate value that an actual flow rate must drop below for a threshold amount of time in order for a second valve associated with a second well to be opened. See Section II.C. Ciezobka does not teach that a measured flow rate must drop below the initial flow rate or any other specific flowrate before one of valves 218 or 219 is opened. Instead, the valve is opened after a specific period of time and without comparing the actual flow rate to the initial flow rate. See Ex. 1037, 12:8– 12 (teaching that a pressure pulse is created by closing valve 219 “for a short period of time” ranging from 1 minute to 1 second, preferably 10 seconds). Indeed, opening valve 218/219 causes flow rate drop to one of the wells; it does not occur as a result of the flow-rate drop.” slip op. at 15
Claim construction§ 102 anticipation§ 103 obviousnessDiscretionary denialcites Phillips · KSR · GrahamPatents in suitUS 11,401,779 - Delta Power Equipment Corporation / Lowe’S Home Centers, LLC et al. v. P & F Brother Industrial CorporationInstitution deniedPTAB · Aug 6, 2024 · IPR2024-00347 · APJ Benjamin D M Wood · IPR · Institution
The Board denied institution because Petitioner did not show a reasonable likelihood that Gass, alone or in the asserted combinations, teaches claim 1’s required bias toward the supporting frame.
In the decision…of Gass biases the front end of the shank away from said supporting frame.” Id. at 10. In support of this assertion Patent Owner refers us to Gass’ teaching that spring 456 “biases clamping plate 442 away from positioning plate 422 to help open the clamp . . .” when handle 490 is raised. Id. at 11…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“shank of bolt 452 towards riving knife 400. Gass teaches that spring 456 applies force to clamping plate 442 to push it away from positioning plate 422. See, e.g., Ex. 1003, 20:60–62 (“Spring 456 biases clamping plate 442 away from positioning plate 422 to help open the clamp . . .”).9 Clamping plate 442 transfers this force to the front end of bolt 452 via the bolt head and cam bushing 470. See id. at 22:11–13, Fig. 53. Because positioning 9 The spring does not apply force to riving knife 400 because the base of the riving knife includes cut-out 502 to allow clearance for bolt 452 and spring 456 when the riving knife is inserted into mounting system 410. Ex. 1003, 22:29–31, Fig. 49. Thus, the spring does not bias the riving knife toward the front end of bolt 452. plate 442 holds riving knife 400 in the mounting system (id. at 20:25–38), pushing clamping plate 442 away from positioning plate 422 effectively biases front end of bolt 452 away from riving knife 400, which is the opposite of what claim 1 requires. Neither Petitioner nor Petitioner’s declarant explain how Gass teaches limitation [1.13] in light of the above teachings. AAPA is relied on to teach a different limitation (Pet. 21–22) and therefore does not cure this deficiency.” slip op. at 18
- Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentableNot shown unpatentable
“shank of bolt 452 towards riving knife 400. Gass teaches that spring 456 applies force to clamping plate 442 to push it away from positioning plate 422. See, e.g., Ex. 1003, 20:60–62 (“Spring 456 biases clamping plate 442 away from positioning plate 422 to help open the clamp . . .”).9 Clamping plate 442 transfers this force to the front end of bolt 452 via the bolt head and cam bushing 470. See id. at 22:11–13, Fig. 53. Because positioning 9 The spring does not apply force to riving knife 400 because the base of the riving knife includes cut-out 502 to allow clearance for bolt 452 and spring 456 when the riving knife is inserted into mounting system 410. Ex. 1003, 22:29–31, Fig. 49. Thus, the spring does not bias the riving knife toward the front end of bolt 452. plate 442 holds riving knife 400 in the mounting system (id. at 20:25–38), pushing clamping plate 442 away from positioning plate 422 effectively biases front end of bolt 452 away from riving knife 400, which is the opposite of what claim 1 requires. Neither Petitioner nor Petitioner’s declarant explain how Gass teaches limitation [1.13] in light of the above teachings. AAPA is relied on to teach a different limitation (Pet. 21–22) and therefore does not cure this deficiency.” slip op. at 18
- PTAB / AIA Trials › Discretionary denial › Fintiv (parallel litigation)Not reached
“F. Patent Owner’s Request for Discretionary Denial of Institution Under 35 U.S.C. § 314(a) Patent Owner requests that we deny institution under 35 U.S.C. § 314(a) because of the related district-court actions listed above. Prelim. Resp. 22–26 (citing Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020)). Because we have determined not to institute inter partes review on the merits, Patent Owner’s request is moot.” slip op. at 19
§ 103 obviousnessDiscretionary denialcites Phillips · KSRPatents in suitUS 7,475,622 - Qualcomm Incorporated / Samsung Electronics Co., Ltd. v. Network System Technologies, LLCInstitution deniedPTAB · Jun 17, 2024 · IPR2024-00355 · APJ Steven M Amundson · IPR · Institution
The Board denied institution because Petitioner did not show a reasonable likelihood of proving any challenged claim unpatentable on the asserted anticipation or obviousness grounds.
In the decision…The “dispositive question regarding anticipation [is] whether one skilled in the art would reasonably understand or infer from the [reference’s] teaching” that it discloses every claim element arranged as in the claim. In re Baxter Travenol Labs., 952 F.2d 388, 390 (Fed. Cir. 1991); see Dayco…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“to institute an inter partes review. We may institute an inter partes review only if “the information presented in the petition filed under section 311 and any response filed under section 313 shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” 35 U.S.C. § 314(a) (2018). The “reasonable likelihood” standard is “a higher standard than mere notice pleading” but “lower than the ‘preponderance’ standard to prevail in a final written decision.” Hulu, LLC v. Sound View Innovations, LLC, IPR2018- 01039, Paper 29 at 13 (PTAB Dec. 20, 2019) (precedential).” slip op. at 2
- PTAB / AIA Trials › Discretionary denial › Fintiv (parallel litigation)Not reached
“Based on Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020) (precedential), Patent Owner argues that we should exercise our discretion under § 314(a) to deny institution in view of the Samsung litigation and the Qualcomm litigation. See Prelim. Resp. 10–22; supra § II.B. Petitioner argues that we should decline to exercise our discretion under § 314(a) to deny institution. See Pet. 82–84. For the reasons explained below, we determine that Petitioner has not demonstrated a reasonable likelihood that it would prevail in proving the unpatentability of at least one claim challenged in the Petition. See infra §§ IV.E–IV.I. Hence, we do not consider discretionary denial under § 314(a).” slip op. at 16
- Skill levelSkill level petitioner adoptedDecided for petitioner
“For purposes of analysis, we adopt Petitioner’s description of an ordinarily skilled artisan because it comports with the technology and claims of the ’893 patent as well as the asserted prior art. For instance, “a master’s degree” and “three years of work experience” would have allowed someone to understand the ’893 patent as well as the asserted prior art. See Ex. 1003 ¶ 32. Moreover, someone with a higher skill level will understand the technology at least as well as someone with a lower skill level. See Innovention Toys, LLC v. MGA Entm’t, Inc., 637 F.3d 1314, 1323 (Fed. Cir. 2011); Tokai Corp. v. Easton Enters., Inc., 632 F.3d 1358, 1369 (Fed. Cir. 2011). Hence, “it is generally easier to establish obviousness under a higher level of ordinary skill.” Kinetic Concepts, Inc. v. Smith & Nephew, Inc., 688 F.3d 1342, 1366 (Fed. Cir. 2012). We note that our analysis would not change if we adopted Patent Owner’s description of an ordinarily skilled artisan.” slip op. at 19
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“for “each data package comprising N data elements” is “significantly broader” than Petitioner’s proposed construction. See Pet. 9–10; Ex. 1026, 25; Ex. 1027 ¶ 164; Ex. 2034, 26. To decide whether Petitioner satisfies the “reasonable likelihood” standard for instituting trial, we must determine the meaning of “each data package comprising N data elements.” Based on the current record, we agree with Petitioner that “each data package comprising N data elements” means “every data package communicated by the network stations has a fixed size of N data elements.”” slip op. at 23
Claim construction§ 102 anticipation§ 103 obviousnessDiscretionary denialcites Phillips · KSR · GrahamPatents in suitUS 8,072,893
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.