• Tesla, Inc. v. Autonomous Devices, LLCSome claims unpatentable
  PTAB · Oct 21, 2025 · IPR2024-00745 · APJ Russell E Cass · IPR · Final written decision

  Claims 45–47, 51, 59, 60, 68, and 69 are unpatentable; claims 56 and 57 are not shown unpatentable. Substitute claims 85–88 and 91 are unpatentable; amendment is granted for claims 92 and 93.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “technical field, and the asserted prior art, we agree with Petitioner’s proposed qualifications for the person of ordinary skill in the art, except we decline to adopt “at least,” as that language is vague and open-ended. Otherwise, Petitioner’s proposed definition is consistent with the level of 3 Patent Owner does not present objective evidence of nonobviousness. skill reflected in the specification of the ’474 patent and the asserted prior art references. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). Accordingly, we adopt Petitioner’s assessment of the level of skill for one of ordinary skill in the art.” slip op. at 11

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther

    “Petitioner states that “no formal constructions are presently necessary,” and that it “maps [the] prior art in this Petition in a manner consistent with Patent Owner’s allegations of infringement before the district court.” Pet. 8 (citing Ex. 1017; Ex. 1003 ¶¶ 21–25). Patent Owner states that it believes there is no need to construe any terms of the challenged original claims because there is no underlying controversy regarding any claim terms. PO Resp. 10. For purposes of this Decision, we determine that it is not necessary to provide an express construction of any claim terms. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017); Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.”).” slip op. at 12

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner

    “3. Motivation to Combine Buibas and Sinyavskiy Petitioner argues that “it would have been obvious to partition Buibas’[s] spiking networks according to the specific techniques disclosed in Sinyavskiy” for multiple reasons. Pet. 13 (citing Ex. 1005 ¶¶ 71–72, 85, 92, 179–203; Ex. 1006 ¶¶ 12, 185, 188, 191, Fig. 6A; Ex. 1003 ¶ 63). First, Petitioner asserts, one of ordinary skill “would have been motivated to partition Buibas’[s] spiking neural network as suggested by Sinyavskiy to parallelize task execution on the robot and improve learning capabilities (e.g., through faster learning, greater computing efficiency, and task-specific learning models) of the Buibas mobile robotic apparatus as described by Sinyavskiy and discussed by Dr. Janet.” Id. (citing Ex. 1003 ¶ 64). Second, Petitioner contends, “partitioning Buibas’[s] robotic brain as suggested by Sinyavskiy would have beneficially expanded the range of tasks that the robot could perform by dedicating partitions to specialized tasks.” Id. at 13– 14 (citing Ex. 1006 ¶¶ 12, 185, 188, Fig. 6A; Ex. 1005 ¶¶ 71–72, 85, 92, 179–205; Ex. 1003 ¶ 65). Third, Petitioner argues, one of ordinary skill “would have been motivated to partition Buibas’[s] spiking neural network as suggested by Sinyavskiy to permit unused partitions or unused resources in the partitions to be reassigned for different tasks,” which would allow for a network processing apparatus that has increased processing capability for the same network capacity while also having a lower cost, size and power consumption. Id. at 14 (citing Ex. 1006 ¶¶ 190–192, 105, 34, code (57); Ex. 1003 ¶ 66). Fourth, Petitioner argues that “Buibas briefly mentions that its spiking neural networks can be partitioned but discloses little detail about the partitioning,” which would invite one of ordinary skill to turn to other references, such as Sinyavskiy, for additional detail on how to implement partitioning. Pet. 14–15 (citing Ex. 1005 ¶ 92; Ex. 1003 ¶ 67). Fifth, Petitioner asserts, combining Buibas and Sinyavskiy would merely “involve[] the application of known techniques (e.g., Sinyavskiy’s partitioned neural network) to a known system (e.g., Buibas’[s] mobile robot and robotic brain) to yield predictable results (e.g., Buibas’[s] robot using a spiking neural network partitioned as taught in Sinyavskiy),” particularly because “the partitioning of the Buibas neural network is reminiscent of Recurrent Fuzzy Neural Networks (RFNNs) that were already commonplace at the end of the 1990’s.” Id. at 15 (citing Ex. 1003 ¶ 68). Finally, Petitioner contends, the proposed combination merely involves “use of known techniques (e.g., Sinyavskiy’s partitioned neural network) to improve a similar system (e.g., Buibas’[s] mobile robot and robotic brain).” Id. (citing Ex. 1003 ¶ 69). Petitioner further argues that one of ordinary skill “would have reasonably expected success implementing the combination, especially as Buibas and Sinyavskiy describe highly similar systems involving spiking neural networks used for training/operating robots.” Pet. 15–16 (citing Ex. 1005 ¶ 92; Ex. 1003 ¶ 70). Indeed, Petitioner contends, “Buibas itself confirms that its spiking neural network can be partitioned, while Sinyavskiy provides the details for doing so.” Id. at 16 (citing Ex. 1005 ¶ 92; Ex. 1003 ¶ 70).” slip op. at 14

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableNot shown unpatentableMixed

    “We agree with Patent Owner and Dr. Saber that these “weights” are numerical values associated with connections among neurons, and the “weight vectors” are merely lists of weights. PO Resp. 13–14; Ex. 2001 ¶¶ 66–67. When input is provided to the neural network, the network uses the weights of its connections in a feedforward calculation manner to provide an output that can include an instruction for operating a device. Ex. 2001 ¶ 66. We agree with and find credible Dr. Saber’s testimony that Buibas’s merging of weights or weight vectors results in updated network weights, and does not, by itself, disclose the merging of instruction sets for operating a device, or the correlation of the same set of inputs for all or a portion of a circumstance representation with instruction sets for operating two different devices. Ex. 2001 ¶¶ 65, 67, 69–71.” slip op. at 39

  Patent outcomesUS 11,663,474 mixed
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,663,474
• Intel Corporation v. Telefonaktiebolaget LM Ericsson (Publ)Some claims unpatentable
  PTAB · Oct 8, 2025 · IPR2024-00728 · APJ Russell E Cass · IPR · Final written decision

  Claims 1–5, 7, 8, 10–15, and 17–19 are unpatentable as obvious; claims 6, 9, and 16 are not shown unpatentable because the Midya-based grounds fail on the terminal limitation.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Based on the full trial record, we continue to adopt Petitioner’s definition of the level of ordinary skill in the art, which is consistent with the ’430 patent and the prior art. In adopting this definition, we note that neither the title nor the “Field of the Invention” portions of the ’430 patent limit the invention to integrated circuits, and Patent Owner does not dispute that claim 1 encompasses inductors that are not provided on an integrated circuit. Ex. 1001, code (54), 1:16–22. Additionally, Dr. Prucnal’s definitions have shifted, and his latest definition purports to be based on Dr. Tentzeris’s characterization of the level of ordinary skill, but changes “experience designing integrated circuits or inductors for semiconductors” to “experience designing integrated circuits and inductors for semiconductors” without sufficient explanation of the reasons for the change. Supp. Prucnal Decl. ¶ 8; Reply Tentzeris Decl. ¶ 56. However, our Decision in this case would not change under Patent Owner’s revised articulation. See Reply Tentzeris Decl. ¶ 57 (stating that his opinion would not change under Patent Owner’s revised definition of the level of ordinary skill).” slip op. at 9

  • Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble not limitingDecided for petitioner

    “After considering the full trial record, we agree with Petitioner that the phrase “on a semiconductor die” in the preamble of claim 11 is not limiting. First, we determine that the phrase “on a semiconductor die” in claim 11 does not provide antecedent basis for terms in the body of the claim. The body of claim 11 does not refer to “the semiconductor die” or even mention the “semiconductor die” at all, and neither do any of the claims that depend from claim 11. We disagree with Patent Owner’s argument that the phrase “on a semiconductor die” in the preamble of claim 11 provides antecedent basis for the term “the first inductor” in the body of the claim, because the “first inductor” language in the preamble provides antecedent basis for “the first inductor” language in the claim’s body. The “on a semiconductor die” language in the preamble is presented separately and can be easily parsed from the preamble’s language reciting a “first inductor” without impacting the understandability or grammatical completeness of claim 11. Therefore, the “on a semiconductor die” language in claim 11’s preamble is not necessary to provide antecedent basis for the phrase “the first inductor” in the body of claim 11. This use of language in claim 11 is distinguishable from the Federal Circuit’s opinion in Deere v. Bush Hog, cited by Patent Owner, where the preamble term “rotary cutter deck” provided antecedent basis for the term “said deck” recited in the claim body, because in Deere, the words “rotary cutter” appeared directly before, directly modified, and were not easily parsed from the term “deck.” See Deere & Co. v. Bush Hog, LLC, 703 F.3d 1349, 1357–58 (Fed. Cir. 2012); PO Resp. 7–8.” slip op. at 12

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for patent owner

    “We agree with Petitioner that claims 1 and 11 do not require that the first and second inductor be laterally spaced, but instead merely require that the second inductor be positioned at a “predetermined distance” from the first inductor. Nothing in the claim language restricts this “predetermined distance” from being in the X, Y, or Z direction, or requires that the inductors be laterally spaced in the same plane. Moreover, the fact that the ’430 patent Specification describes embodiments where the inductors are laterally spaced in the same plane does not limit the claims to those embodiments. As explained previously, our reviewing court “has expressly rejected the contention that if a patent describes only a single embodiment, the claims of the patent must be construed as being limited to that embodiment.” Liebel-Flarsheim, 358 F.3d at 906. “Even when the specification describes only a single embodiment, the claims of the patent will not be read restrictively unless the patentee has demonstrated a clear intention to limit the claim scope using ‘words or expressions of manifest exclusion or restriction.’” Id. We see no such “words or expressions of manifest exclusion or restriction” here. Accordingly, we give the term “predetermined distance” its ordinary meaning, which includes a distance in any direction. The parties do not dispute that Taniguchi’s inductors are spaced apart with an insulation layer in between. Therefore, under the ordinary meaning of the claim language, Taniguchi’s second inductor is “positioned at a predetermined distance from the first inductor.”” slip op. at 26

  • Prior constructionPrior construction adoptedDecided for patent owner

    “We agree with and adopt the ITC’s construction of “closely spaced,” which is “two terminals in proximity to each other (such that the electromagnetic field at a certain distance from the first inductor (where the second inductor is positioned) is reduced.” Ex. 1020, 12. We find that this construction is supported by the intrinsic record, including the Specification of the ’430 patent, which shows terminals being “closely spaced” compared to the dimensions of the inductor itself, and explains that the purpose of the close spacing is to make the field contributions from the two parts of the inductor identical. See Ex. 1005, Figs. 1–2, 4:28–32. Claims 1 and 11 of the ’430 patent lack specific dimensions for either the inductor or the spacing between the terminals, and indicate that the purpose of the close spacing is to “minimiz[e] magnetic field contributions from the terminals.” Ex. 1001, 10:22–25, 11:7–10. Dr. Prucnal’s ITC declaration, although not intrinsic evidence, further supports our conclusion. Although Patent Owner does not propose a construction for “closely spaced terminals,” it appears to argue that this term must be interpreted based on the dimensions of the semiconductor chip described in the ’430 patent. PO Resp. 43. We do not see any basis in the intrinsic or extrinsic evidence to impart such a narrow reading to the claim language, particularly because the ’430 patent Specification does not define the “closely spaced terminals” in relation to a semiconductor chip, and claim 1 is not limited to inductors on a semiconductor chip.” slip op. at 40

  Patent outcomesUS 7,151,430 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 7,151,430
• Luminex International Co., Ltd. / Menard, Inc. v. Signify Holdings B.V.Some claims unpatentable
  PTAB · Aug 13, 2025 · IPR2024-01469 · APJ Steven M Amundson · IPR · Final written decision

  Claims 1–7, 9–15, and 18–20 are unpatentable; claims 8, 16, and 17 are not determined unpatentable under the asserted prior-art grounds.

  RulingsFinal written decision

  • PTAB / AIA Trials › §315(b) time barNot time barredDecided for petitioner

    “G. Analysis 1. REAL PARTY IN INTEREST Based on the record before us and for the reasons explained below, we disagree with Patent Owner that Menard is a “real party in interest” under § 315(b). See Resp. 77–82; Sur-reply 27–28. First, the circumstances here differ materially from the circumstances in Ventex. There, two agreements defined the relationship between Ventex (the petitioner and manufacturer of Heatwave fabric) and Seirus (the alleged real party in interest and purchaser of Heatwave fabric). Ventex, IPR2017- 00651, Paper 152 at 7 & n.8. First, a 2013 Supplier Agreement “prevented Ventex from selling to Seirus competitors” and included an indemnity provision requiring Ventex to indemnify Seirus for losses arising from Ventex’s failure to perform certain obligations. Id. at 7, 14. Second, a 2016 Exclusive Manufacturing Agreement provided that Ventex would manufacture the Heatwave fabric only for Seirus in exchange for Seirus’s payment of an exclusivity fee. Id. at 7. Columbia (the patent owner) accused Seirus products incorporating the Heatwave fabric of infringing the patent at issue, and Columbia served Seirus with a complaint alleging patent infringement in 2014 more than two years before Ventex filed a petition in 2017. Id. at 5, 7. When determining that Seirus was a “real party in interest” under § 315(b), the Board reasoned that “Ventex and Seirus had a specially structured, preexisting, and well established business relationship with one another, including indemnification and exclusivity arrangements.” Ventex, IPR2017-00651, Paper 152 at 10; see id. at 12. Additionally, the Board noted that certain evidence “suggest[ed] that” slip op. at 32

  • PTAB / AIA Trials › Real party in interest / privityRpi dispute resolved for petitionerDecided for petitioner

    “G. Analysis 1. REAL PARTY IN INTEREST Based on the record before us and for the reasons explained below, we disagree with Patent Owner that Menard is a “real party in interest” under § 315(b). See Resp. 77–82; Sur-reply 27–28. First, the circumstances here differ materially from the circumstances in Ventex. There, two agreements defined the relationship between Ventex (the petitioner and manufacturer of Heatwave fabric) and Seirus (the alleged real party in interest and purchaser of Heatwave fabric). Ventex, IPR2017- 00651, Paper 152 at 7 & n.8. First, a 2013 Supplier Agreement “prevented Ventex from selling to Seirus competitors” and included an indemnity provision requiring Ventex to indemnify Seirus for losses arising from Ventex’s failure to perform certain obligations. Id. at 7, 14. Second, a 2016 Exclusive Manufacturing Agreement provided that Ventex would manufacture the Heatwave fabric only for Seirus in exchange for Seirus’s payment of an exclusivity fee. Id. at 7. Columbia (the patent owner) accused Seirus products incorporating the Heatwave fabric of infringing the patent at issue, and Columbia served Seirus with a complaint alleging patent infringement in 2014 more than two years before Ventex filed a petition in 2017. Id. at 5, 7. When determining that Seirus was a “real party in interest” under § 315(b), the Board reasoned that “Ventex and Seirus had a specially structured, preexisting, and well established business relationship with one another, including indemnification and exclusivity arrangements.” Ventex, IPR2017-00651, Paper 152 at 10; see id. at 12. Additionally, the Board noted that certain evidence “suggest[ed] that” slip op. at 32

  • Skill levelOther

    “C. Level of Ordinary Skill in the Art Factors pertinent to determining the level of ordinary skill in the art include (1) the educational level of the inventor; (2) the type of problems encountered in the art; (3) prior-art solutions to those problems; (4) the rapidity with which innovations are made; (5) the sophistication of the technology; and (6) the educational level of workers active in the field. Envtl. Designs, Ltd. v. Union Oil Co., 713 F.2d 693, 696–97 (Fed. Cir. 1983). Not all factors may exist in every case, and one or more of these or other factors may predominate in a particular case. Id. These factors are not exhaustive, but merely a guide to determining the level of ordinary skill in the art. Daiichi Sankyo Co. v. Apotex, Inc., 501 F.3d 1254, 1256 (Fed. Cir. 2007). Moreover, the prior art itself may reflect an appropriate skill level. Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). Petitioner asserts that a person of ordinary skill in the art at the ’336 patent’s effective filing date would have had “a bachelor’s degree in mechanical engineering, electrical engineering, optics, or physics with at least three years of experience working in the design of LED lights or lighting fixtures; a master’s degree in one of the above disciplines with at least two years of experience; or equivalent experience.” Pet. 14 (citing Ex. 1004 ¶¶ 26–29). Dr. Eden’s testimony supports Petitioner’s assertion. See Ex. 1004 ¶¶ 27–28. Patent Owner “adopts for purposes of this proceeding only” Petitioner’s description of an ordinarily skilled artisan. Resp. 10 (citing Pet. 14). We adopt Petitioner’s description of an ordinarily skilled artisan because it comports with the technology and claims of the ’336 patent as” slip op. at 40

  • Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia no nexusDecided for petitioner

    “Alleged Objective Indicia of Nonobviousness (i) General Principles Before reaching a conclusion about obviousness, we consider evidence concerning objective indicia of nonobviousness. See Apple, 839 F.3d at 1048. For such evidence to have substantial weight, “its proponent must establish a nexus between the evidence and the merits of the claimed invention.” ClassCo, Inc. v. Apple, Inc., 838 F.3d 1214, 1220 (Fed. Cir. 2016); see Ancora Techs., Inc. v. Roku, Inc., 140 F.4th 1351, 1361 (Fed. Cir. 2025) (noting that the Board did not err by requiring “a nexus to the challenged claims as opposed to the patent as a whole”). “[T]here is no nexus unless the evidence presented is ‘reasonably commensurate with the scope of the claims.’” ClassCo, 838 F.3d at 1220 (quoting Rambus Inc. v. Rea, 731 F.3d 1248, 1257 (Fed. Cir. 2013)). The patentee “bears the burden of showing that a nexus exists.” WMS Gaming, Inc. v. Int’l Game Tech., 184 F.3d 1339, 1359 (Fed. Cir. 1999). A rebuttable presumption of nexus arises “when the patentee shows that the asserted objective evidence is tied to a specific product and that product ‘embodies the claimed features, and is coextensive with them.’” Fox Factory, Inc. v. SRAM, LLC, 944 F.3d 1366, 1373 (Fed. Cir. 2019) (quoting Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1072 (Fed. Cir. 2018)). Whether a rebuttable presumption of nexus arises “turns on the nature of the claims and the specific facts.” Teva Pharms. Int’l GmbH v. Eli Lilly & Co., 8 F.4th 1349, 1362 (Fed. Cir. 2021). The presumption analysis should consider the unclaimed features in the product tied to the objective evidence to assess their significance and impact on the correspondence between the patented invention and the product. Quanergy Sys., Inc. v. Velodyne Lidar USA, Inc., 24 F.4th 1406, 1418 (Fed. Cir. 2022). When, “for example, the patented invention is only a small component of the product tied to the objective evidence, there is no presumption of nexus.” Henny Penny Corp. v. Frymaster LLC, 938 F.3d 1324, 1333 (Fed. Cir. 2019). Absent a presumption of nexus, the patentee may prove nexus by” slip op. at 76

  Patent outcomesUS 10,299,336 mixed
  § 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,299,336
• Luminex International Co., Ltd. / Menard, Inc. v. Signify Holdings B.V.Some claims unpatentable
  PTAB · Aug 13, 2025 · IPR2024-00101 · APJ Steven M Amundson · IPR · Final written decision

  Claims 1–7, 9–15, and 18–20 are unpatentable; claims 8, 16, and 17 are not shown unpatentable under the asserted grounds.

  RulingsFinal written decision

  • PTAB / AIA Trials › Real party in interest / privityRpi dispute resolved for patent ownerDecided for patent owner

    “G. Analysis 1. REAL PARTY IN INTEREST Based on the record before us and for the reasons explained below, we” slip op. at 32

  • PTAB / AIA Trials › §315(b) time barDecided for patent owner

    “III. WHETHER THE PETITION IS TIME BARRED The parties dispute whether the Petition is time barred based on a” slip op. at 18

  • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted

    “vacated the panel’s decision denying institution. Paper 12, 6. Among other things, the Director determined based on a “review of the current record” that (1) Menard is not a real party in interest in this proceeding and (2) Menard is not a privy of Petitioner. Id. at 5. Further, the Director remanded the case to the panel and instructed the panel “to determine whether the Petition presents a reasonable likelihood of prevailing with respect to at least one of the challenged claims under 35 U.S.C. § 314(a), and to determine whether to institute inter partes review accordingly.” Id. at 5–6.” slip op. at 3

  • BurdenMixed

    “U.S. Patent No. 10,299,336 B2 (“the ’336 patent”) (Exhibit 1001). For the reasons explained below, a preponderance of the evidence shows that claims 1–7, 9–15, and 18–20 in the ’336 patent are unpatentable and does not show that claims 8, 16, and 17 are unpatentable. See 35 U.S.C. § 316(e) (2024).” slip op. at 2

  Patent outcomesUS 10,299,336 mixed
  § 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,299,336
• Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Resonant Systems, Inc.Some claims unpatentable
  PTAB · Jan 8, 2025 · IPR2023-00993 · APJ Michael T Cygan · IPR · Final written decision

  Claims 1, 2, 7, 8, 11, 15–17, and 20 are unpatentable under § 103; claims 3–6, 9, 14, and 19 were not shown unpatentable.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art [“POSITA”] at the critical time “would have had a bachelor’s degree in electrical engineering, mechanical engineering, computer science, or a similar field and two years of experience related to electronic consumer product design [and the] POSITA could have also obtained similar knowledge and experience through other means.” Pet. 6 (citing Ex. 1003 ¶ 31). Patent Owner states that it would require experience with electro-mechanical control systems rather than electronic consumer product design. PO Resp. 3. Because Petitioner provides for “similar knowledge and experience through other means,” we do not discern any meaningful distinction. Thus, we adopt Petitioner’s proposed level of ordinary skill, as it appears to be consistent with the specification of the ’830 patent and the prior art of record.” slip op. at 7

  • Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)§112(f) appliesDecided for patent owner

    “Determining whether a limitation that does not use the term “means” invokes § 112, paragraph 6, involves a three-part inquiry: (1) there is a generic placeholder that substitutes for the term “means”; (2) the generic placeholder is modified by functional language; and (3) the limitation does not include the structure, material, or acts necessary to perform the function in question without need to resort to other portions of the specification or extrinsic evidence for an adequate understanding of the structure. See Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1349 (Fed. Cir. 2015); Tri-Med, Inc. v. Stryker Corp., 514 F.3d 1256, 1259–60 (Fed. Cir. 2008); Rodime PLC v. Seagate Tech., Inc., 174 F.3d 1294, 1303–04 (Fed. Cir. 2015) (the court must “determine whether the claim nevertheless recites sufficient structure for performing the . . . function to take it outside the bounds of” § 112, paragraph 6).” slip op. at 8

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached

    “Limitation [1b] With respect to limitation [1b], a “moveable component,” Petitioner argues that it should be construed as a means (component) having a function (moveable) that corresponds to a structure (a moving weight). Pet. 7. Petitioner argues that “essentially any physical component can perform the function of being moved,” references different types of structure as the moving components in the ’830 patent, and concludes that therefore the term has no definite structure. Pet. Reply 2 (citing Ex. 1001, Figs. 4A–4G, 14, 15–17). Patent Owner argues for a non-means-plus-function construction of a component that “is capable of being moved.” PO Resp. 7–8 (citing Ex. 2008 ¶ 55). Patent Owner argues, and Petitioner agrees, that “there is likely no material difference between” the parties’ proffered constructions such that construction is necessary. Id. at 8; Pet. Reply 7. We agree, because Petitioner has shown, and Patent Owner does not contest, that the prior art teaches such a component under either construction. Infra § II(D)(2)(a). Because Petitioner’s assertions and our determination would be unaffected by its proposed construction, we need not construe this term. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (noting that “we 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))).” slip op. at 9

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

    “We agree with Patent Owner that a showing of motivation is required. Whether a proposed combination rests on “combining disclosures from multiple references, combining multiple embodiments from a single reference, or selecting from large lists of elements in a single reference, there must be a motivation to make the combination and a reasonable expectation that such a combination would be successful.” In re Stepan Co., 868 F.3d 1342, 1346 n.1 (Fed. Cir. 2017). The General Electric decision cited by Petitioner does not hold otherwise. In General Electric, the Federal Circuit considered an obviousness challenge based on combining disclosures from multiple references. See Gen. Elec., 983 F.3d at 1339–40, 1344–52. The Federal Circuit criticized the Board for dissecting an embodiment disclosed in the primary reference into a collection of “individual elements” and requiring the patent challenger to “re-do the work already done” regarding that embodiment in the primary reference. Id. at 1351–52. The Federal Circuit did not consider an obviousness challenge based on combining multiple embodiments from a single reference. See id. at 1344–52. Therefore, we do not agree with Petitioner that no motivation to combine the Figure 3 and Figure 83 embodiments of Fukumoto need be shown.” slip op. at 29

  Patent outcomesUS 9,941,830 mixed
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,941,830
• Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Resonant Systems, Inc.Some claims unpatentable
  PTAB · Jan 8, 2025 · IPR2023-00992 · APJ Steven M Amundson · IPR · Final written decision

  Claims 1, 2, 7, 8, 11, and 17 are unpatentable; claims 3–6, 9, and 14 are not shown unpatentable, and claims 15 and 16 were disclaimed.

  RulingsFinal written decision

  • Skill levelSkill level patent owner adoptedDecided for patent owner

    “B. Level of Ordinary Skill in the Art Factors pertinent to determining the level of ordinary skill in the art include (1) the educational level of the inventor; (2) the type of problems encountered in the art; (3) prior-art solutions to those problems; (4) the rapidity with which innovations are made; (5) the sophistication of the technology; and (6) the educational level of workers active in the field. Envtl. Designs, Ltd. v. Union Oil Co., 713 F.2d 693, 696–97 (Fed. Cir. 1983). Not all factors may exist in every case, and one or more of these or other factors may predominate in a particular case. Id. These factors are not exhaustive, but merely a guide to determining the level of ordinary skill in the art. Daiichi Sankyo Co. v. Apotex, Inc., 501 F.3d 1254, 1256 (Fed. Cir. 2007). Moreover, the prior art itself may reflect an appropriate skill level. Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). Petitioner asserts that a person of ordinary skill in the art at the time of the alleged invention “would have had a bachelor’s degree in electrical engineering, mechanical engineering, computer science, or a similar field and two years of experience related to electronic consumer product design.” 3 The parties do not provide evidence or argument regarding objective indicia of nonobviousness. See, e.g., Pet. 9–93; Resp. 18–66. Pet. 6. Petitioner also asserts that an ordinarily skilled artisan “could have also obtained similar knowledge and experience through other means.” Id. Dr. Wolfe’s testimony supports Petitioner’s assertions. See Ex. 1003 ¶ 30. Patent Owner asserts that a person of ordinary skill in the art at the time of the alleged invention “would have had (1) a bachelor’s degree in electrical engineering, mechanical engineering, or a comparable field of study, and (2) at least two years of professional experience with electro-mechanical control systems, or other similarly relevant industry experience.” Resp. 3. Patent Owner also asserts that “[a]dditional relevant industry experience may compensate for lack of formal education or vice versa.” Id. Dr. Goossen’s testimony supports Patent Owner’s assertions. See Ex. 2008 ¶ 16.” slip op. at 15

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for patent owner

    “10. SUMMARY “[O]nly those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.” Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999); see Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017). Above, we discussed issues concerning the “component” limitations in claims 1, 3, and 4 and an ambiguity in claim 4. See supra §§ III.C.4(c), III.C.5(c), III.C.6(c), III.C.7(c), III.C.8(c), III.C.9. We determine that no other claim language requires a discussion of scope or an explicit construction to decide whether Petitioner satisfies the “preponderance of the evidence” standard for proving unpatentability. D. Alleged Obviousness over Fukumoto: Claims 1–3, 7–9, and 17 Petitioner contends that claims 1–3, 7–9, and 17 are unpatentable under § 103(a) because the claims would have been obvious over Fukumoto. See Pet. 9–35; Reply 16–22. Patent Owner disputes Petitioner’s contentions. See Resp. 18–27; Sur-reply 7–14. Below, we provide an overview of Fukumoto. Then, we consider the obviousness issues. For the reasons explained below, we agree with Petitioner that claims 1, 2, 7, and 17 are unpatentable under § 103(a) because the claims would have been obvious over Fukumoto but disagree that claims 3, 8, and 9 are unpatentable based on Fukumoto.” slip op. at 44

  • Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)§112(f) does not applyDecided for patent owner

    “2. MEANS-PLUS-FUNCTION CLAIMING The patent statute provides that “[a]n element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.” 35 U.S.C. § 112 ¶ 6 (2006). The absence of the word “means” in a claim limitation creates a rebuttable presumption that § 112’s means-plus-function provision does not apply. Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1348 (Fed. Cir. 2015) (en banc in relevant part). When a claim limitation lacks the word “means,” a party may rebut the presumption that § 112’s means-plus-function provision does not apply by demonstrating that “the claim term fails to ‘recite[] sufficiently definite structure’ or else recites ‘function without reciting sufficient structure for performing that function.’” Williamson, 792 F.3d at 1348 (alteration by the court) (quoting Watts v. XL Sys., Inc., 232 F.3d 877, 880 (Fed. Cir. 2000)). Construing a means-plus-function limitation involves two steps: first, identify the claimed function or functions; and second, determine what structure, if any, disclosed in the patent’s specification corresponds to the claimed function or functions. Williamson, 792 F.3d at 1351; see Medtronic, Inc. v. Advanced Cardiovascular Sys., Inc., 248 F.3d 1303, 1311 (Fed. Cir. 2001). For the second step, a person of ordinary skill in the art must “recognize the structure in the specification and associate it with the corresponding function in the claim.” All-Voice Computing PLC v. Nuance Commc’ns, Inc., 504 F.3d 1236, 1241 (Fed. Cir. 2007). The “duty to link or associate structure to function is the quid pro quo for the convenience” of using means-plus-function claiming. B. Braun Med., Inc., v. Abbott Lab’ys, 124 F.3d 1419, 1424 (Fed. Cir. 1997). When a limitation recites two or more functions, the specification” slip op. at 18

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable

    “Conclusion About Obviousness/Nonobviousness For the reasons discussed above, Fukumoto teaches claim 1’s subject” slip op. at 64

  Patent outcomesUS 9,369,081 mixed
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,369,081
• Netflix, Inc. v. Gotv Streaming, LLCSome claims unpatentable
  PTAB · Nov 5, 2024 · IPR2023-00758 · APJ Steven M Amundson · IPR · Final written decision

  Claims 1–3, 5–10, 12–14, and 16–21 are unpatentable as obvious over Hariki and Harris; claims 4, 11, 15, and 22–33 were not shown unpatentable.

  RulingsFinal written decision

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMixed

    “in the browser,” e.g., content resulting from HTML files received from the web server. Ex. 2029, 68:15–18. Accordingly, an ordinarily skilled artisan “would have understood that customizing” the “application program environment or display and sound aspects of the device” using a UI content package “would mean that the converted resources (i.e., ‘custom configuration’) of the UI content package were applicable to all HTML files received from the web server and displayed” by the web browser program. Ex. 1002 ¶ 159; see Ex. 1005 ¶¶ 19, 24, 42.” slip op. at 105

  • ExcludeMotion to exclude, deniedDenied

    “FURTHER ORDERED that Petitioner’s motion to exclude evidence (Paper 30) is dismissed as moot; and” slip op. at 134

  Patent outcomesUS 8,478,245 mixed
  § 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,478,245
• Netflix, Inc. v. Gotv Streaming, LLCSome claims unpatentable
  PTAB · Nov 5, 2024 · IPR2023-00757 · APJ Steven M Amundson · IPR · Final written decision

  Claims 1, 2, 4–10, and 12–16 are unpatentable as obvious over Hariki and Harris; claims 3, 11, and 17–20 were not shown unpatentable.

  RulingsFinal written decision

  • Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia no nexusDecided for patent owner

    “Alleged Objective Indicia of Nonobviousness (i) General Principles Before reaching a conclusion about obviousness, we consider evidence concerning objective indicia of nonobviousness. See Apple, 839 F.3d at 1048. For such evidence to have substantial weight, the patentee “must establish a nexus between the evidence and the merits of the claimed invention.” ClassCo, 838 F.3d at 1220. “[T]here is no nexus unless the evidence presented is ‘reasonably commensurate with the scope of the claims.’” Id. (quoting Rambus Inc. v. Rea, 731 F.3d 1248, 1257 (Fed. Cir. 2013)). The patentee “bears the burden of showing that a nexus exists.” WMS Gaming, Inc. v. Int’l Game Tech., 184 F.3d 1339, 1359 (Fed. Cir. 1999). A rebuttable presumption of nexus arises “when the patentee shows that the asserted objective evidence is tied to a specific product and that product ‘embodies the claimed features, and is coextensive with them.’” Fox Factory, Inc. v. SRAM, LLC, 944 F.3d 1366, 1373 (Fed. Cir. 2019) (quoting Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1072 (Fed. Cir. 2018)). Whether a rebuttable presumption of nexus arises “turns on the nature of the claims and the specific facts.” Teva Pharms. Int’l GmbH v. Eli Lilly & Co., 8 F.4th 1349, 1362 (Fed. Cir. 2021). The presumption analysis should consider the unclaimed features in the product tied to the objective evidence to assess their significance and impact on the correspondence between the patented invention and the product. Quanergy Sys., Inc. v. Velodyne Lidar USA, Inc., 24 F.4th 1406, 1418 (Fed. Cir. 2022). When, “for example, the patented invention is only a small component of the product tied to the objective evidence,” and thus the product is not coextensive with the patented invention, “there is no presumption of nexus.” Henny Penny Corp. v. Frymaster LLC, 938 F.3d 1324, 1333 (Fed. Cir. 2019). Absent a presumption of nexus, the patentee may prove nexus by showing that the objective evidence resulted directly from “the unique characteristics of the claimed invention.” Fox Factory, 944 F.3d at 1373–74; see In re Huang, 100 F.3d 135, 140 (Fed. Cir. 1996). For example, “[a] prima facie case of nexus is generally made out when the patentee shows both that there is commercial success, and that the thing (product or method) that is commercially successful is the invention disclosed and claimed in the patent.” Demaco Corp. v. F. Von Langsdorff Licensing Ltd., 851 F.2d 1387, 1392 (Fed. Circ. 1988).” slip op. at 113

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMixed

    “Conclusion About Obviousness/Nonobviousness For the reasons discussed above, the combined disclosures in Hariki” slip op. at 119

  • ExcludeMotion to exclude, deniedNot reached

    “In our analyses above, we do not rely on any of Exhibits 2023 to 2027. See, e.g., supra §§ III.C.2–III.C.4. Hence, we dismiss Petitioner’s motion to exclude evidence as moot. See, e.g., Volkswagen Grp. of Am., Inc. v. Spero, IPR2023-00335, Paper 40 at 24 (PTAB July 15, 2024) (dismissing motion to exclude evidence as moot).” slip op. at 135

  Patent outcomesUS 8,989,715 mixed
  § 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,989,715
• Keysight Technologies, Inc. / Palo Alto Networks, Inc. v. Centripetal Networks, LLCSome claims unpatentable
  PTAB · Aug 5, 2024 · IPR2023-01353 · APJ Kevin F Turner · IPR · Final written decision

  Claims 1–4, 6–11, and 13–20 are unpatentable as obvious over Sourcefire and Emerging Threats; claims 5 and 12 were not shown unpatentable.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner, supported by Dr. Staniford’s testimony, proposes that a person of ordinary skill in the art at the time of the invention “would have had a bachelor’s degree in computer science, computer engineering, or an equivalent, and four years of industry experience,” and “would have had a working knowledge of packet-switched networking, firewalls, security policies, communication protocols and layers, and the use of customized rules to address cyber-attacks.” Pet. 16 (citing Ex. 1003 ¶¶ 23, 25). Patent Owner does not challenge the qualifications proposed by Petitioner for a person of ordinary skill in the art. See generally PO Resp. We find Petitioner’s proposal consistent with the level of ordinary skill in the art reflected by the prior art of record, see Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978), and, therefore, we adopt Petitioner’s unopposed position as to the level of ordinary skill in the art for purposes of this Decision” slip op. at 7

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Plain and ordinary meaningNo construction neededOther

    “We largely agree with Patent Owner that there is no explicit claim- construction dispute. We address Patent Owner’s issues of what ordinarily skilled artisans would have considered in creating and implementing packetfiltering rules in the discussion below. The preservation of the flow of normal legitimate network traffic without disruption is one aspect that those with a working knowledge of packet-switched networking, firewalls, security policies, communication protocols and layers, and the use of customized rules to address cyber-attacks would have considered. Nonetheless, overall, we determine that the plain and ordinary meaning of “configured to prevent an exfiltration operation,” does not require preventing all exfiltrations from occurring, nor allowing all non-exfiltration traffic, and that we need not consider the preservation of the flow of normal legitimate network traffic without disruption in the context of that claim construction. We determine that no claim terms need to be construed expressly for purposes of this Decision.” slip op. at 10

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication establishedDecided for petitioner

    “We agree with Petitioner. The identified aspects of Emerging Threats website would have allowed interested parties to locate the rule sets, download the rule sets and make determinations regarding what rule to use in a packet-handling system, such as Sourcefire. Emerging Threats need not be indexed or broadly searchable under Petitioner’s theory of the ground of unpatentability, namely that Emerging Threats was known, one of ordinary skill in the art would have gone to Emerging Threats, and downloaded the emerging-all.rules file, guided by the documentation wiki. As such, we do not agree with Patent Owner’s argument that “the record evidence of this” slip op. at 16

  • PTAB / AIA Trials › §315(e) estoppelEstoppel appliesDecided for petitioner

    “With respect to Petitioner’s assertions of collateral estoppel, notably in the Petition at pages 47, 49, 51, 52, and 54, with respect to limitations [1a] through [1d], we agree with Petitioner that Patent Owner is estopped from asserting that Sourcefire is not prior art to the challenged claims, and also estopped from asserting that those limitations are not taught or suggested by Sourcefire, to the extent that the limitations “do not materially alter the question” of patentability relative to the elements of the claims of the ’552 patent. See Soverain Software LLC v. Victoria’s Secret Direct Brand Mgmt., LLC, 778 F.3d 1311, 1319 (Fed. Cir. 2015). Independent Claim 1 a. Petitioner’s Assertions As discussed above, we concur with Petitioner that collateral estoppel exists with respect to limitations [1a] through [1d]. Thus, we begin with a discussion of Petitioner’s assertions regarding claim limitation [1e].” slip op. at 21

  Patent outcomesUS 10,567,343 mixed
  Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,567,343
• Keysight Technologies, Inc. / Palo Alto Networks, Inc. v. Centripetal Networks, LLCSome claims unpatentable
  PTAB · Aug 5, 2024 · IPR2023-00446 · APJ Kevin F Turner · IPR · Final written decision

  Claims 1–4, 6–11, and 13–20 are unpatentable as obvious over Sourcefire and Emerging Threats; claims 5 and 12 were not shown unpatentable.

  RulingsFinal written decision

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication establishedDecided for petitioner

    “We agree with Petitioner. The identified aspects of Emerging Threats website would have allowed interested parties to locate the rule sets, download the rule sets and make determinations regarding what rule to use in a packet-handling system, such as Sourcefire. Emerging Threats need not be indexed or broadly searchable under Petitioner’s theory of the ground of unpatentability, namely that Emerging Threats was known, one of ordinary skill in the art would have gone to Emerging Threats, and downloaded the emerging-all.rules file, guided by the documentation wiki. As such, we do not agree with Patent Owner’s argument that “the record evidence of this” slip op. at 16

  • PTAB / AIA Trials › §315(e) estoppelEstoppel appliesDecided for petitioner

    “With respect to Petitioner’s assertions of collateral estoppel, notably in the Petition at pages 47, 49, 51, 52, and 54, with respect to limitations [1a] through [1d], we agree with Petitioner that Patent Owner is estopped from asserting that Sourcefire is not prior art to the challenged claims, and also estopped from asserting that those limitations are not taught or suggested by Sourcefire, to the extent that the limitations “do not materially alter the question” of patentability relative to the elements of the claims of the ’552 patent. See Soverain Software LLC v. Victoria’s Secret Direct Brand Mgmt., LLC, 778 F.3d 1311, 1319 (Fed. Cir. 2015). Independent Claim 1 a. Petitioner’s Assertions As discussed above, we concur with Petitioner that collateral estoppel exists with respect to limitations [1a] through [1d]. Thus, we begin with a discussion of Petitioner’s assertions regarding claim limitation [1e].” slip op. at 21

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner

    “how and why persons of ordinary skill in the art would have modified the existing rules to prevent exfiltrations. PO Sur-reply 3. Patent Owner also argues that Petitioner’s assertions to make them “drop” rules, per Sourcefire, relies on what an administrator could have done, not what they would have been motivated to do. Id. at 4–5 (citing Pet. 57–58). We disagree with Patent Owner’s arguments. We continue to be persuaded that one of ordinary skill in the art, combining Sourcefire and Emerging Threats, would have understood that downloaded rules should be reviewed, and it would have been obvious to enable rules that such persons deemed appropriate. We find Dr. Staniford’s testimony to be persuasive on this point. See Ex. 2011, 67:10–68:24, 69:8–72; Ex. 1020, 109. We acknowledge that downloading all of a particualr ruleset from Emerging Threats and enabling all the rules, might have resulted in a drop in performance of the network appliance, but, at the same time, we are significant drop in performance, especially if a potential threat might be sufficient to warrant a minor performance hit. Patent Owner’s counsel acknowledged at oral hearing that instituting all rules of a set in “alert” mode would not result in a decrease in performance, even though some computational outlay must be engaged to engage those alert rules. See Hr’g Tr. 24:24–25:4. We are persuaded that judiciously implementing certain rules would not necessary result in a network device that is unusable. Additionally, there is testimony from Dr. Staniford that “you start out with your rules in alert because there might be false positives. I mean, for the best rule in the world, Snort wasn’t known for false positives in the rules, when you apply them to a large network.” Ex. 2011, 68:2–7. As such, we continue to determine that it would have been obvious, in combining Sourcefire with Emerging Threats, for one of ordinary skill in the art to have downloaded rules and implemented specific rules.” slip op. at 24

  • Obviousness (§103) › Motivation to combine / reasonable expectation of success › HindsightDecided for petitioner

    “Reviewing all of the evidence of record, we are persuaded that the Petition’s obviousness rationale based on Sourcefire and Emerging Threats is not guided by impermissible hindsight bias. We find persuasive Dr. Staniford’s testimony that one of ordinary skill in the art would have understood that “this rule [SID:2003021] was not directed to looking for instances of exploits or attacks (which would be invisible within the encryption) but rather was looking for exfiltration of some kind of encrypted data.” Ex. 1003 ¶ 228. As discussed by Petitioner, such recognition was also made by Mr. Marinho and Dr. Goodrich, such that the rule would have been understood to possibly prevent exfiltrations. We continue to be persuaded that Petitioner provides that a correspondence exists between the REQUIRE-TLS-1.1-1.2 operator in the ’343 Patent and SID:2003021 in Emerging Threats, in that both detect an SSL/TLS version in application packet header field values to detect exfiltration attempts using out-of-date encryption protocols. Pet. 43 (citing Ex. 1003 ¶¶ 229–230). We are ’343 Patent discloses the interruption of a similar type of exfiltration, without resorting to impermissible hindsight bias, that Patent Owner asserts. Patent Owner has provided no evidence that Petitioner used the specification of the ’343 Patent to find an applicable rule in Emerging Threats, as opposed to the testified-version provided by Dr. Staniford that he recalls “working on a similar feature where we looked for large encrypted transmissions outbound from the network on non-HTTP ports as a possible symptom of exfiltration of large amounts of data.” Ex. 1003 ¶ 228. Thus, we are not persuaded by Patent Owner’s arguments.” slip op. at 30

  Patent outcomesUS 10,567,343 mixed
  Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,567,343

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.