- Satco Products, Inc. v. Seoul Semiconductor Co., Ltd.Some claims unpatentablePTAB · Oct 22, 2021 · IPR2020-00836 · APJ Erica A Franklin · IPR · Final written decision
Claims 1, 10, 15, 18, and 21 are unpatentable; claims 2, 3, 11, 12, 17, and 19 were not shown unpatentable.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“B. Person of Ordinary Skill in the Art The level of skill in the art is a factual determination that provides a” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed board ownDecided for petitioner
“take issue with the Board’s construction of ‘phase voltage’ in the Institution Decision as it does not implicate any dispute here.” PO Resp. 3. In the Reply, Petitioner also does not challenge the Board’s preliminary determination. See generally Pet. Reply. Having considered the record as a whole, we see no reason to depart from our preliminary finding. Accordingly, we find that the Specification defines “phase voltage,” i.e.,” slip op. at 14
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner
“dimming circuit’ that must be part of the ‘driver circuit,’” without requiring it to be completely distinct from the phase switch or other elements of the driver circuit. Pet. Reply 5. Accordingly, we decline to adopt Patent Owner’s proposed construction that limits the dimming circuit to “a circuit, separate and distinct from the phase switches, that provides a dimming effect.” See PO Resp. 25. Instead, we recognize the ordinary and customary meaning for the “dimming circuit,” i.e., any circuit comprised in the driver circuit that is capable of providing a dimming effect.” slip op. at 28
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“proposed construction for “phase switch.” Rather, as discussed above, we have found that the Specification broadly defines the term without requiring the device to determine when to turn itself on or off. As defined in the Specification, “The phase switch is a general term to indicate any device that, when turned on, conducts electrical current.” Ex. 1001, 3:43–44 (emphasis added). There is no dispute between the parties that Chiang’s CCUs are devices that, when turned on, conduct electrical current. Accordingly, we find that Petitioner has shown by a preponderance of the evidence that Chiang’s CCUs are a “plurality of phase switches.”” slip op. at 36
Patent outcomesUS 7,081,722 mixedClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 7,081,722 - Liquidia Technologies, Inc. v. United Therapeutics CorporationSome claims unpatentablePTAB · Oct 8, 2021 · IPR2020-00770 · APJ John E Schneider · IPR · Final written decision
Claims 1–5, 8, and 9 are unpatentable as obvious over Moriarty and Phares; claims 6 and 7 were not shown unpatentable over either asserted ground.
RulingsFinal written decision- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for patent owner
“Claim terms need only be construed to the extent necessary to resolve the controversy. Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011). Here, we do not need to define the outer bounds of the term “pharmaceutical batch” because the parties’ dispute over this term centers on the issue of storage stability.7 Patent Owner argues “the correct construction 6 The parties use the terms “purification” and “isolation” interchangeably in the papers. We use the term “isolation” in this Decision. 7 The parties agree on the “pharmaceutical” aspect of the term. We note the ’901 patent defines “pharmaceutically acceptable” as “being useful in preparing a pharmaceutical composition that is generally safe, non-toxic and neither biologically nor otherwise undesirable and includes being useful for veterinary use as well as human pharmaceutical use.” Ex. 1001, 5:27–31.” slip op. at 19
- Claim Construction › Intrinsic evidence (Phillips canons) › Prosecution history disclaimer / disavowalTerm construed patent owner constructionDecided for patent owner
“[A]n invention is construed not only in the light of the claims, but also with reference to the file wrapper or prosecution history in the Patent Office.” Graham, 383 U.S. 1, 33. “The prosecution history of a related patent can be relevant if . . . it addresses a limitation in common with the patent in suit.” Advanced Cardiovascular Sys., Inc. v. Medtronic, Inc., 265 F.3d 1294, 1305 (Fed. Cir. 2001); see also Elkay Mfg. Co. v. Ebco Mfg. Co., 192 F.3d 973, 980 (Fed. Cir. 1999) (“When multiple patents derive from the same initial application, the prosecution history regarding a claim limitation in any patent that has issued applies with equal force to subsequently issued patents that contain the same claim limitation.”). Here, the Specification of the ’901 patent includes the same language “crude treprostinil salts can be stored as raw material at ambient temperature” addressed in the prosecution of the parent ’623 application. Ex. 1001, 17:5–6. More importantly, challenged claim 6 recites the same limitation “preparing a pharmaceutical product . . . after storage” the applicant expressly interpreted there. See Ex. 2028, 193. Because “the same claim limitation is at issue, prosecution disclaimer made on the same limitation in an ancestor application will attach,” the applicant’s interpretation of “storing”/“storage” during the prosecution of the ’623 application applies here. See Omega Eng’g, Inc., v. Raytek Corp., 334 F.3d 1314, 1333 (Fed. Cir. 2003). slip op. at 23
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed patent owner constructionDecided for patent owner
“Sunovion Pharm., Inc. v. Teva Pharm. USA, Inc., 731 F.3d 1271, 1276 (Fed. Cir. 2013). Here, step (c) of challenged claim 1 requires “contacting the solution comprising treprostinil from step (b) with a base to form a salt of treprostinil.” Ex. 1001, 17:27–29 (emphasis added). The claim language itself, thus, dictates that the solution formed in step (b), and not treprostinil isolated from step (b), is the starting material for forming a salt in step (c). The Specification of the ’901 patent supports our determination. Indeed, the Specification touts that one of the advantages of the disclosed process is that “the treprostinil salts can be synthesized from the solution of treprostinil without isolation,” because “[t]he impurities carried over from intermediate steps (i.e. alkylation of triol and hydrolysis of benzindene nitrile) are removed during the carbon treatment and the salt formation step.” Ex. 1001, 17:1–11. As a result, we agree with the argument presented in the Patent Owner Response that “claim 1 requires the solution in which treprostinil is formed be used directly in the next salt-forming step without isolating treprostinil in between.” See PO Resp. 11.” slip op. at 27
- Skill levelSkill level board ownOther
“pharmaceutical manufacturing.” Id. at 23. We find Patent Owner’s definition of the skill level too narrow. Patent Owner relies on the declaration of Dr. Pinal, who testifies that the ’901 patent is “focused on the production of pharmaceutical compositions and products, on a commercial batch-size scale.” Ex. 2002 ¶ 91; see also id. ¶ 92 (opining that organic and medicinal chemists do not have the “requisite skill set for the large-scale manufacture” of drugs); PO Resp. 24 (arguing an ordinarily skilled artisan is aware of “problems encountered in preparing a commercial-scale pharmaceutical product”).” slip op. at 29
Patent outcomesUS 9,604,901 mixedClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 9,604,901 - Merck Sharp & Dohme Corp. v. Wyeth LLCSome claims unpatentablePTAB · Jun 8, 2018 · IPR2017-00380 · APJ Erica A Franklin · IPR · Final written decision
Claims 1–6, 10, 11, 14, 17, 19, and 20 are unpatentable as obvious over Prevenar and Chiron; claim 18 was not shown unpatentable.
RulingsFinal written decision- Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed petitioner constructionDecided for petitioner
“Based on the record as a whole, we determine that the Specification sets forth with reasonable clarity, deliberateness, and precision the definition of the term “polysaccharide,” as accurately represented by Petitioner, and acknowledged by Patent Owner. With respect to the phrase “polysaccharide-protein conjugates,” the Specification does not provide a” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner
“similarly precise definition. However, the Specification generally describes such conjugates in a manner that is consistent with the plain and ordinary meaning of the phrase. For example, the Specification explains that polysaccharides are “chemically activated (e.g., via reductive amination) to make the saccharides capable of reacting with the carrier protein.” Ex. 1001, 17:35–37. The Specification also explains that “[c]arrier proteins should be amenable to standard conjugation procedures.” Id. at 17:47–50. In particular, the Specification states, “[t]he chemical activation of the polysaccharides and subsequent conjugation to the carrier protein (i.e., a polysaccharide-protein conjugate) are achieved by conventional means.” Id. at 17:43–45. Moreover, as Patent Owner asserts, the Specification describes the polysaccharide-protein conjugates as an example of an “immunogenic composition.” Ex. 1001, 1:29–30. In light of those Specification descriptions, we determine that the broadest reasonable construction of the claim phrase “polysaccharide-protein conjugates” refers to an immunogenic composition resulting from reacting any antigenic saccharide element (or antigenic unit) commonly used in the immunologic and bacterial vaccine arts, including, but not limited to, a saccharide, an oligosaccharide, a polysaccharide, a liposaccharide, a lipo-oligosaccharide, a lipopolysaccharide, a glycosylate, a glycoconjugate, and the like with a carrier protein that is amenable to standard conjugation procedures.” slip op. at 10
- Skill levelSkill level patent owner adoptedDecided for patent owner
“In the Institution Decision, we adopted Patent Owner’s description of the level of ordinary skill at that stage in the proceeding because it included a requirement for experience relating to polysaccharide-protein conjugates. Dec. Inst. 13. Based on the record as a whole, we determine that a declarant having significant experience relating to protein-silicone oil interactions also offers useful information relating to the subject matter of the challenged claims. Thus, we also recognize those having ordinary skill in the art relating to silicone-induced interactions/aggregation in pharmaceuticals. Thus, we adopt Patent Owner’s description of one having ordinary skill in the art of formulating polysaccharide-protein conjugate immunogenic compositions. Further, we describe one having ordinary skill in the art of silicone-induced interactions/aggregation in pharmaceuticals as either (a) a Ph.D. degree in the pharmaceutical sciences, physical chemistry or protein chemistry, at least two years of work experience involving researching silicone-induced interactions/aggregation in pharmaceuticals, or (b) a Master’s degree in the pharmaceutical sciences, physical chemistry or protein chemistry, at least four years of work experience involving researching silicone-induced interactions/aggregation in pharmaceuticals.” slip op. at 15
- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
“inadequately supported by the testimony of Drs. Morefield (Ex. 2121) and Thomson (Ex. 2124). The portions of the declarations of Drs. Morefield and Thomson relied upon by the Patent Owner do not refer to any evidence to support their opinions that a histidine buffer would not be a beneficial addition to the Prevenar formulation. Rather, those discussions sound of unsubstantiated theoretical concerns, and are speculative at best. At worst, certain of those theories has been refuted in the art. For example, Petitioner directs us to the testimony of one of its declarants, Dr. HogenEsch, who has a Ph.D. in Pathology and Immunology. Reply 13–16. Dr. HogenEsch explains persuasively that, contrary to the speculation of Drs. Morefield and Thomson, “histidine buffer had specifically been reported . . . not to interact with aluminum adjuvant through ligand exchange.” Ex. 1122 ¶ 43. In support of this testimony, Dr. HogenEsch quotes a disclosure from US Patent No. 6,251,678 B17 explaining that, although phosphate-containing buffers are generally not preferred because they may interact with aluminum adjuvants, “the non interaction of histidine . . . buffers with aluminum adjuvant was demonstrated by zeta potential measurements of the surface charge of the aluminum adjuvant.” Id. (quoting Ex. 1109, 3:24–30). We find that the unsupported testimony offered by Patent Owner’s declarants to be outweighed by rebuttal testimony from Dr. HogenEsch and the express disclosures by Chiron relied upon by Petitioner. Generally, as Petitioner and Dr. Kalonia note, Chiron teaches that buffers are a standard component of vaccines. Pet. 40; Ex. 1009 ¶ 128 (citing Ex. 1011, 1:6–7). More specifically, as Petitioner asserts, Chiron teaches that adding histidine buffer to aluminum-adjuvanted pneumococcal CRM197 conjugate formulations comprising a sodium salt is advantageously biocompatible and” slip op. at 23
Patent outcomesUS 8,562,999 mixedClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,562,999 - Merck Sharp & Dohme Corp. v. Wyeth LLCSome claims unpatentablePTAB · Jun 8, 2018 · IPR2017-00378 · APJ Erica A Franklin · IPR · Final written decision
Claims 1–6, 10, 11, 14, 17, 19, and 20 are unpatentable as obvious over Chiron, Smith, and Elan; claim 17 is also unpatentable with Peña. Claim 18 was not shown unpatentable.
RulingsFinal written decision- Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed petitioner constructionDecided for petitioner
“claim term “polysaccharide” is set forth in the Specification. Pet. 37–42. In particular, the Specification defines “polysaccharide” as including “any antigenic saccharide element (or antigenic unit) commonly used in the immunologic and bacterial vaccine arts, including, but not limited to, a ‘saccharide’, an ‘oligosaccharide’, a ‘polysaccharide’, a ‘liposaccharide’, a ‘lipo-oligosaccharide (LOS)’, a ‘lipopolysaccharide (LPS)’, a ‘glycosylate’, a ‘glycoconjugate’ and the like.” Ex. 1001, 16:32–38. Patent Owner similarly acknowledges that the term “polysaccharide” is expressly defined in the Specification. PO Resp. 11.” slip op. at 7
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner
“In light of those Specification descriptions, we determine that the broadest reasonable construction of the claim phrase “polysaccharide-protein conjugates” refers to an immunogenic composition resulting from reacting any antigenic saccharide element (or antigenic unit) commonly used in the immunologic and bacterial vaccine arts, including, but not limited to, a saccharide, an oligosaccharide, a polysaccharide, a liposaccharide, a lipo-oligosaccharide, a lipopolysaccharide, a glycosylate, a glycoconjugate, and the like with a carrier protein that is amenable to standard conjugation procedures. Although we recognize that the claimed invention is directed toward an immunogenic composition, we also note that the claims do not recite any specific level of immunogenicity for the composition. The Specification explains that the invention “broadly relates to novel formulations which stabilize and inhibit precipitation of immunogenic compositions.” Ex. 1001, 2:53–55. The Specification describes aggregation as an indicator of physical/thermal stability of the immunogenic composition. Id. at 2:7–8. Breakdown of the composition to an undesired form (e.g., an aggregate) lowers the total concentration of the product. Id. at 1:43–46. Insofar as Patent Owner asserts that the claims require “measuring antigenicity to determine the extent of the loss of antigenicity due to silicone-induced aggregation,” as in Example 4 of the Specification, PO Resp. 14, we disagree. Although Example 4 discusses total antigenicity (and loss), the claims do not require the formulation to retain a particular degree of immunogenicity. Instead, the claims are directed to a formulation comprising a polysaccharide-protein conjugate, i.e., an “immunogen,” see, e.g., Ex. 1001, 14:19–23, wherein the formulation inhibits aggregation6 induced by the siliconized container means. The presence of a polysaccharide-protein conjugate confers the immunogenic element of the claim. While performing an immunoassay to measure loss of antigenicity, as in Example 4, may provide information regarding whether silicone-induced aggregation has occurred, such an assay is not required to meet the “protein-polysaccharide conjugate” element of the claim. Moreover, as explained in each example described in the Specification, the occurrence of aggregation/precipitation may be detected upon visual inspection. See, e.g., Ex. 1001, 27:6–11 (discussing visual inspection for precipitation).” slip op. at 10
- Skill levelSkill level patent owner adoptedDecided for patent owner
“In the Institution Decision, we adopted Patent Owner’s description of the level of ordinary skill at that stage in the proceeding because it included a requirement for experience relating to polysaccharide-protein conjugates. Dec. Inst. 12–13. Based on the record as a whole, we determine that a declarant having significant experience relating to protein-silicone oil interactions also offers useful information relating to the subject matter of the challenged claims. Thus, we also recognize those having ordinary skill in the art relating to silicone-induced interactions/aggregation in pharmaceuticals. Thus, we adopt Patent Owner’s description of one having ordinary skill in the art of formulating polysaccharide-protein conjugate immunogenic compositions. Further, we describe one having ordinary skill in the art of silicone-induced interactions/aggregation in pharmaceuticals as either (a) a Ph.D. degree in the pharmaceutical sciences, physical chemistry or protein chemistry, at least two years of work experience involving researching silicone-induced interactions/aggregation in pharmaceuticals, or (b) a Master’s degree in the pharmaceutical sciences, physical chemistry or protein chemistry, at least four years of work experience involving researching silicone-induced interactions/aggregation in pharmaceuticals. We also note that the applied prior art reflects the appropriate level of skill at the time of the claimed invention. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). We recognize each of Petitioner’s and Patent Owner’s declarants as qualified to provide the offered opinions on the level of skill and the knowledge of a person of ordinary skill in the art at the time of the invention with respect to formulating polysaccharide-protein conjugates and/or silicone-induced interactions/aggregation in pharmaceuticals. The relative weight that we assign such testimony, however, is subject to additional factors. See, e.g., Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,763 (Aug. 14, 2012) (“Opinions expressed without disclosing the underlying facts or data may be given little or no weight.”).” slip op. at 15
- Expert testimonyPetitioner expert creditedDecided for petitioner
“We credit Dr. Kalonia’s testimony that a skilled artisan would have used a siliconized container to store Chiron’s formulation with persuasive weight, as that testimony is supported by Smith’s disclosure, as discussed above. On the other hand, we find that Patent Owner’s assertions and the related opinions by its declarants, e.g., Drs. Morefield (Ex. 2120) and Thomson (Ex. 2123), that a person of ordinary skill would not have found it obvious to use siliconized containers to store Chiron’s formulations are inadequately supported. For example, Patent Owner relies upon Dr. Morefield’s testimony that a siliconized container would not have been used in Chiron’s Example 8 because (a) the example involved a saccharide stability study, and introducing a siliconized container would have injected an unknown parameter into the experiment, and (b) the data demonstrates that the formulation was highly unstable. PO Resp. 25 (citing Ex. 2120 ¶¶ 36–42). However, Dr. Morefield has not provided any evidence to suggest that a siliconized container represented an “unknown” parameter. Rather, as evidenced by Smith and Elan, it was a known parameter, with a known solution. Nor has Dr. Morefield accurately characterized the data disclosed in Chiron’s Example 8 as demonstrating Chiron’s formulation was “highly unstable.” Chiron expressly concludes from the data in Example 8 that “[f]ree saccharide levels are thus stable for at least 1 month at 2–8°C, before and after packaging,” and that stability issues arose for two formulations, MenW125 and Men Y, only “[u]nder thermal stress conditions.” Ex. 1011, 16:3–6.” slip op. at 27
Patent outcomesUS 8,562,999 mixedClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,562,999 - Atlas Copco Airpower N.V. v. Kaeser Kompressoren SESome claims unpatentablePTAB · Dec 23, 2016 · IPR2015-01421 · APJ Erica A Franklin · IPR · Final written decision
Claims 1, 2, 4, 5, 7–12, and 14–20 are unpatentable; claim 13 was not shown unpatentable, because White did not teach the claimed input-compressor control.
RulingsFinal written decision- Expert testimonyPetitioner expert creditedDecided for petitioner
“Based upon our review of Dunne and the supporting testimony of Dr. Knaebel, whose opinion, in this regard, we afford persuasive weight, we agree with Petitioner that Dunne discloses each element of claim 1, including inherently disclosing two alternative embodiments wherein a pressure increasing device is provided within the connecting line to increase pressure of the gas flowing from the second discharging line to the second feeding line. In particular, we are persuaded that a person of ordinary skill in the art would understand that Dunne teaches that the compression required by paragraph 26 may optionally be provided in either stream 7 or 9, shown in Dunne’s Figure 1. Each of those streams may be seen as “going to the adsorption zone” and providing an opportunity for compression “prior to contacting the adsorbent wheel,” as required by Dunne. Ex. 1002 ¶ 26. Further, compression in any of those streams is consistent with the teaching in paragraph 27 of Dunne that compression may occur “prior to or after the condenser on the regeneration or cooling effluent,” i.e., Figure 1 shows that compression occurs in stream 7 prior to reaching the condenser and in stream 9 after the condenser, wherein each of those streams may be considered a regeneration effluent as they flow from the regeneration sector.” slip op. at 16
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Patent Owner does not provide a statement describing a person of ordinary skill in the art. Nor does Patent Owner provide the testimony of a declarant purported to be such a person. Based upon our review of the record as a whole, we find that Petitioner’s statement regarding the qualifications of a person of ordinary skill in the art is sound and supported by the evidence. Accordingly, we adopt Petitioner’s description. Moreover, we recognize Dr. Knaebel as a person of ordinary skill in the art.” slip op. at 11
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownOther
“The Specification explains that the pressure increasing device is provided to “increase the pressure of the gas flowing from the second discharging line to the second feeding line.” Ex. 1001, 3:46–48. The Specification also explains that the pressure increasing device “may be a mechanical compressor, in particular a compressor and/or a fan and/or a pump and/or a side-channel compressor and/or a turbo compressor, e.g., a radial compressor.” Ex. 1001, 5:46–49. Independent claim 1 describes the connecting line by reciting, in part, “the second discharging line being in communication with the second feeding line and thus forming a connecting line.” Based upon our consideration of those descriptions and the Specification as a whole, we construe the phrase “a pressure increasing device provided within the connecting line” broadly to mean a device, such as a mechanical compressor, in particular a compressor, fan, pump, side-channel compressor, and/or a turbo compressor, e.g., a radial compressor, provided within the line formed between the second discharging line and the second feeding line, wherein the device increases pressure of gas flowing from the second discharging line to the second feeding line.” slip op. at 8
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“Based upon our review of Dunne and the supporting testimony of Dr. Knaebel, whose opinion, in this regard, we afford persuasive weight, we agree with Petitioner that Dunne discloses each element of claim 1, including inherently disclosing two alternative embodiments wherein a pressure increasing device is provided within the connecting line to increase pressure of the gas flowing from the second discharging line to the second feeding line. In particular, we are persuaded that a person of ordinary skill in the art would understand that Dunne teaches that the compression required by paragraph 26 may optionally be provided in either stream 7 or 9, shown in Dunne’s Figure 1. Each of those streams may be seen as “going to the adsorption zone” and providing an opportunity for compression “prior to contacting the adsorbent wheel,” as required by Dunne. Ex. 1002 ¶ 26. Further, compression in any of those streams is consistent with the teaching in paragraph 27 of Dunne that compression may occur “prior to or after the condenser on the regeneration or cooling effluent,” i.e., Figure 1 shows that compression occurs in stream 7 prior to reaching the condenser and in stream 9 after the condenser, wherein each of those streams may be considered a regeneration effluent as they flow from the regeneration sector. Further, Petitioner has shown persuasively, and Patent Owner has not argued otherwise, that streams 7 and 9 depicted in Dunne’s Figure 1 make up a “connecting line in which a condenser 8 is provided” as required by claim 1. Pet. 28–30. Thus, we determine that Dunne’s inherent disclosure of providing a pressure increasing device in either of streams 7 or 9, results in two embodiments of the invention which necessarily meet all of the limitations in claim 1, including providing a pressure increasing device within the connecting line to increase the gas flowing from the second discharging line to the second feeding line.” slip op. at 16
Patent outcomesUS 8,349,054 mixedClaim construction§ 102 anticipation§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,349,054
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.