- Yealink (USA) Network Technology Co., Ltd. / Yealink Network Technology Co., Ltd. v. Barco NVNo claims unpatentablePTAB · Oct 5, 2026 · IPR2025-00598 · APJ David C Mckone · IPR · Final written decision
Claims 1–31 were not shown unpatentable under either § 103 ground because the asserted combinations did not teach required claim limitations.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedOther
“admissions by Patent Owner in litigation, contends that a person of ordinary skill in the art would have had “a Master of Science (M.S.) degree in electrical engineering or computer science, and five years of work experience in a related field” and that “[a]dditional educational experience could substitute for some of the work experience.” Pet. 5 (citing Ex. 1002 ¶¶ 36–37). “Patent Owner does not dispute Petitioner’s proposed level of skill in the art (Petition, 5) at this time.” PO Resp. 6. On the complete record, we adopt Petitioner’s description of the level of ordinary skill in the art, as it is uncontested and is consistent with the technology described in the ’347 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“In the Preliminary Response, “Patent Owner accept[ed] the Petition’s claim construction.” Prelim. Resp. 6. However, in the Patent Owner Response, Patent Owner argues that “the claims of the ’347 Patent require no construction as they are valid under their plain and ordinary meaning.” PO Resp. 6. Based on the complete record, we do not find it necessary to provide express claim constructions of any claim terms. 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
- Expert testimonyPetitioner expert discountedDecided for patent owner
“Beel actually discloses the following: [0321] On the peripheral device 32 the video packets are received at the corresponding plug and play port, e.g. the USB port 11, read by the Human Interface Driver (HID) interface handler 13, unpacked to remove HID protocol headers in an unpacker 20 and then transmitted to the communications network by a transmitter 21. The network can be wireless for example WiFi or LiFi network. [0322] Having been routed over a communications network to the base unit 33, the incoming stream is read from the communications interface such as a WiFi access point 22, unpacked in an unpacker 25, decoded in a decoder 26 and then inserted into a suitable composition such as an OpenGL based composition in the compositor 29 for display on a central display device. Ex. 1005 ¶¶ 321–322 (emphasis added to portions quoted by Petitioner). Patent Owner notes that “[t]he Petition mistakenly cites to ¶ 322 of Beel but quotes ¶ 321.” PO Resp. 20 n.3. However, it appears that Petitioner has grafted together a portion of paragraph 321 that introduces peripheral device 32 with a portion of paragraph 322, which discusses features of base unit 33. However, this grafting has been done in such a way as to convey (incorrectly) that peripheral device 32, not base unit 33, includes unpacker 25, decoder 26, and compositor 29 that process the first processed video data received by the first peripheral device to generate second video data. Dr. Almeroth’s testimony, which copies Petitioner’s incorrectly altered quotation to paragraph 322 of Beel, is unreliable as to this claim limitation and is entitled to no weight.4 Thus, Petitioner has no expert testimony on which to rely for this claim limitation.” slip op. at 19
- Strike new argumentNew argument disregardedDecided for patent owner
“5 At the oral argument, when challenged on its reliance on paragraph 322, Petitioner argued that paragraph 321 of Beel teaches this limitation. Tr. 22:26–23:24. Petitioner did not make this argument in the Petition and, instead, raised it for the first time during oral argument; thus, it will not be considered. See Dell Inc. v. Acceleron, LLC, 884 F.3d 1364, 1369 (Fed. Cir. 2018) (“Unless it chose to exercise its waiver authority under 37 C.F.R. § 42.5(b), the Board was obligated to dismiss Dell’s untimely argument given that the untimely argument in this case was raised for the first time during oral argument.”). Even if we were to consider this new argument, it would not be persuasive. As Patent Owner observes (PO Resp. 20), any processing performed by peripheral device 32 in paragraph 321 is on data received from the processing device and destined for the base station via the network, rather than data flowing in the direction of the first processed video data of claim 1.” slip op. at 22
Patent outcomesUS 11,966,347 not shown unpatentableClaim construction§ 103 obviousnesscites Phillips · GrahamPatents in suitUS 11,966,347 - Apple Inc. v. Proxense, LLCAll claims unpatentablePTAB · Sep 17, 2026 · IPR2025-00562 · APJ Thu A Dang · IPR · Final written decision
Claims 1–20 are unpatentable as obvious over Giobbi ’157, Giobbi ’139, and Dua; the Board also finds the claims unpatentable under the Broadcom grounds.
RulingsFinal written decision- Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)§112(f) does not applyDecided for petitioner
“IPR2024-00783, Ex. 1001, 22:36–49. As the Federal Circuit stated, when a disputed claim limitation does not employ “means for” language, the presumption is that each of the terms conveys sufficiently definite structure or act and, thus, is not subject to § 112 ¶ 6. See Dyfan, 28 F.4th at 1367. Based on the record before us, this presumption that each of the terms is not subject to § 112 ¶ 6 is not overcome.” slip op. at 17
- Skill levelOther
“differences between the claimed subject matter and the prior art are such that the subject matter, as a whole, “would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains.” KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007). The question of obviousness is resolved on the basis of underlying factual determinations including: (1) the scope and content of the prior art; (2) any differences between the claimed subject matter and the prior art; (3) the level of ordinary skill in the art; and (4) objective evidence of non-obviousness. See Graham v. John Deere Co. of Kansas City, 383 U.S. 1, 17–18 (1966).” slip op. at 25
- Expert testimonyPetitioner expert creditedDecided for petitioner
“We find persuasive Dr. Wolfe’s supporting testimony that a POSITA would have understood the terms “PDK” and “RDC” to have “definite structure.” Ex. 1013 ¶¶ 35–56. In particular, we find persuasive Dr. Wolfe’s testimony that the term “PDK,” for example, “encompasses at least ‘a collection of circuit components that includes an antenna, a transceiver, and a controller and memory for storing information particular to a user.’” Id. ¶ 35. Dr. Wolfe’s testimony is consistent with the Specification of the ’188 patent. See Ex. 1001, 5:42–6:7, 3:48–62. In particular, the Specification of the ’188 patent describes a microchip that stores information in memory and responds through an antenna when probed, which is consistent with Dr. Wolfe’s testimony. Id.; Ex. 1001, 1:30–62.” slip op. at 19
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“differences between the claimed subject matter and the prior art are such that the subject matter, as a whole, “would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains.” KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007). The question of obviousness is resolved on the basis of underlying factual determinations including: (1) the scope and content of the prior art; (2) any differences between the claimed subject matter and the prior art; (3) the level of ordinary skill in the art; and (4) objective evidence of non-obviousness. See Graham v. John Deere Co. of Kansas City, 383 U.S. 1, 17–18 (1966).” slip op. at 25
Patent outcomesUS 9,049,188 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 9,049,188 - Amazon.Com, Inc. / Amazon.Com Services LLC et al. v. Soundclear Technologies LLCAll claims unpatentablePTAB · Jul 27, 2026 · IPR2025-00565 · APJ Michael R Zecher · IPR · Final written decision
Claims 1–5 are unpatentable because Amazon showed they are anticipated by Shin; the Board did not reach Amazon’s contingent obviousness ground over Shin.
RulingsFinal written decision- BurdenOther
“Written Decision under 35 U.S.C. § 318(a) as to the patentability of claims 1–5 of the ’337 patent. For the reasons we identify below, we hold that Amazon has demonstrated by a preponderance of the evidence that these claims are unpatentable.” slip op. at 2
- Skill levelOther
“2. Level of Skill in the Art In determining whether an invention would have been obvious, we” slip op. at 18
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“1. Principles of Law To establish anticipation, “all of the elements and limitations of the” slip op. at 17
- Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableNot shown unpatentableMixed
“1. Principles of Law To establish anticipation, “all of the elements and limitations of the” slip op. at 17
Patent outcomesUS 11,069,337 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,069,337 - Yealink (USA) Network Technology Co. Ltd. / Yealink Network Technology Co., Ltd. v. Barco N.V.All claims unpatentablePTAB · Apr 7, 2026 · IPR2024-01439 · APJ Frederick C Laney · IPR · Final written decision
Claims 1–11 and 13–21 are unpatentable under § 103 based on Ono and Corbett and Uchida and Grimshaw; the Board did not find Ichieda unpatentable.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“B. Level of Ordinary Skill in the Art Petitioner contends that a person having ordinary skill in the art would have had at least a Master’s Degree in Electrical Engineering with . . . five years of work experience in computer science and embedded systems, or Master’s Degree in Computer Science with . . . five years of work experience in electrical and computer engineering and embedded systems. Additional educational experience could substitute for some of the work experience. level of skill in the art.” PO Resp. 10. We adopt Petitioner’s proposed definition of a person of ordinary skill in the pertinent art, as it is consistent with the ’951 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“determine that none of the claim terms the parties provide constructions for require an express construction in this proceeding. See Realtime Data LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019). The parties do appear to disagree on the meaning of “trigger,” however. Although neither party actually identifies that term as needing interpretation and neither party actually provides a claim construction analysis to support its respective position, the parties do dispute whether the evidence presented shows a “trigger,” both presumably giving that term its plain and customary meaning. In other words, while both parties appear to agree “trigger” carries its plain meaning, in application, the parties’ dispute regarding the particular limitations including that term appears to turn, not over what the evidence discloses, but only on whether the disclosure satisfies the plain meaning of “trigger” (see infra § II.E.2). Accordingly, while we apply the plain meaning of “trigger” in this proceeding, and in doing so, we address which party has properly applied the plain meaning and, in doing that, we address the scope properly afforded to “trigger.” That analysis, however, is done below in the context of the limitation in which this issue arises (see id.).” slip op. at 8
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner
“has now been developed, and in view of both parties’ arguments, we find Petitioner has persuasively shown that modifying Ono’s peripheral device (i.e., communications module 44) to include an input device/physical actuator like the one described for Ono’s remote controller 69 to control the display of image data from a particular user’s computer would have been obvious to a skilled artisan at the time of the invention. More specifically, Petitioner has shown persuasively Ono shows that the use of an input device/physical actuator to send a signal that causes a participant’s computer to transmit and control the image data presented on a shared display in an image display system was a known technique (see Ex. 1005 ¶¶ 7, 44–48, 66– 71, 77–78, 80–89, 144, Figs. 3, 6, 8, 9; Ex. 1002 ¶¶ 85–100, 121–127) and available location for such an input device/physical actuator to initiate the transmission of data (see Ex. 1007 ¶¶ 6, 18, 20, 22–23, 26, 28, 46, Fig. 1; Ex. 1002 ¶¶ 92–100). Petitioner has also persuasively shown that a skilled artisan recognized benefits to giving a participant the ability to locally control the display of their computer’s image data. See Ex. 1002 ¶¶ 87–91; Ex. 1008 ¶¶ 4, 19–20, 27–28; Ex. 1009 ¶¶ 10–13, 39–10, 70–72. When Ono and Corbett are considered together as a whole from the perspective of a skilled artisan, therefore, it is clear that applying a similar input device/physical actuator to Ono’s peripheral device would have been recognized to result in the benefit of providing a participant with the same ability to send a signal that causes a participant’s computer to transmit and control the image data presented on a shared display from their computer within an image display system. As a result, a motivation has been established because the combination is an application of a known technique to derive a known benefit using prior art elements according to their established functions. Intel Corp. v. PACT XPP Schweiz AG, 61 F.4th 1373, 1380 (Fed. Cir. 2023).” slip op. at 24
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“that, from their perspective, the plain meaning of the term “trigger” does not exclude intervening steps between a user’s action on an input device and the ultimate transfer of the user selected arbitrary media content. Pet. Reply 11– 12 (indicating that “trigger” encompasses “a process that begins with and thus is triggered by a user pressing a button followed by an ‘image transfer’ from a PC to a projector”). For its part, Patent Owner maintains (at least implicitly) that intervening steps are excluded from the plain meaning. Neither party addresses with more specificity why, or why not, the scope of “trigger” supports their positions, however. Having now the complete record before us, we find that out preliminary assessment was wrong because the plain meaning of the term “trigger” does not exclude intervening steps between the cause-and-effect relationship of the trigger and the result it is intended to cause. Take, for example, a simple gun. Pulling the “trigger” to fire a gun necessarily includes intervening steps to occur: the trigger releases a hammer that, in turn, contacts a blasting cap within a bullet casing, which is what actually causes the gunpowder to ignite (i.e., fire) and expel the bullet. And there is no evidence in this record to suggest that this customary understanding of the word “trigger” is any different in the electrical arts, other than the trigger and result are generally electrical in nature, rather than mechanical. We find no clear disavowal of claim scope within the intrinsic record of the ’951 patent to indicate that the term “trigger” was intended to be understood any differently to exclude any intervening steps between a user’s action on an input device and the resulting transfer of user selected arbitrary media content. intervening steps would exist because the input device does not actually do the transferring of the media content; instead, the claims recite the transferring is “from the transmitter to the wireless communications network and [then] to the base node.” See Ex. 1001, 11:3–48, 27:62–28:1 (claim 1), 28:62–67 (claim 9), 29:42–46 (claim 16), 30:36–44 (claim 21) (emphasis added). A skilled artisan would have recognized that there would be intervening steps between the input device being acted upon and the content being displayed by base node’s display. See Ex. 1083 ¶¶ 11–12. In the claims, the input device is analogous to a gun’s trigger, the user carrying out a user action on the input device is analogous to pulling a gun’s trigger, and the transfer of user selected arbitrary media content is analogous the gun expelling a bullet. In both cases, there can be, and usually are, intervening steps, moreover, in both cases, inadvertent things can happen that may prevent the intended result (e.g., in the case of a gun, the hammer can jam; in the case of an input device, a connection can be rejected). Nevertheless, in both cases, the trigger is the thing that initiates an automated process that leads to a particular result, unless a conditional error occurs.” slip op. at 31
Patent outcomesUS 11,422,951 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,422,951 - Yealink (USA) Network Technology Co., Ltd. / Yealink Network Technology Co., Ltd. v. Barco N.V.All claims unpatentablePTAB · Apr 7, 2026 · IPR2024-01437 · APJ Meredith C Petravick · IPR · Final written decision
Claims 1, 3, 9, 18, and 19 are unpatentable as obvious over Kaplan and Mardiks and over Maeda and Deforche.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner contends that a person having ordinary skill in the art would have had at least a Master’s Degree in Electrical Engineering and five years of work experience in computer science and embedded systems, or a Master’s Degree in Computer Science and five years of work experience in electrical and computer engineering and embedded systems. Additional educational experience could substitute for some of the work experience. Pet. 9 (citing Ex. 1002 ¶¶ 36–37). ordinary skill in the art. PO Resp. 10. We adopt Petitioner’s proposed definition of a person of ordinary skill in the pertinent art, as it is consistent with the ’237 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“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). Petitioner and Patent Owner propose constructions for a number of claim terms. Pet. 9–14; PO Resp. 8–10. Only those terms in controversy, however, need to be construed, and only to the extent necessary to resolve the controversy. Realtime Data LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019). We need not construe explicitly any claim term.” slip op. at 8
- Expert testimonyPetitioner expert creditedDecided for petitioner
“a) Whether Dr. Almeroth’s Testimony should Be Given Little Weight Patent Owner argues that we should give little weigh to the testimony of Dr. Almeroth because Dr. Almeroth’s testimony is allegedly inconsistent across the related inter partes reviews. PO Resp. 11–16; PO Sur-reply 21– 22. We have reviewed the disputed portions of Dr. Almeroth’s testimony and, when read in context, we are not persuaded that the testimony is inconsistent so as to be afforded little weight. As Petitioner points out (Pet. Reply 2), Patent Owner’s arguments do not properly account for the context in which the testimony was given in the related inter partes reviews.” slip op. at 16
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“Two separate tests define the scope of analogous prior art: (1) whether the art is from the same field of endeavor, regardless of the problem addressed and, (2) if the reference is not within the field of the inventor’s endeavor, whether the reference still is reasonably pertinent to the Deutschland Gmbh v. Mylan Pharms. Inc., 66 F.4th 1373, 1377 (Fed. Cir. 2023) (quoting In re Bigio, 381 F.3d 1320, 1325 (Fed. Cir. 2004) (citations omitted). We are persuaded by Petitioner that Mardiks meets at least the second test because both the ’237 patent and Mardiks “are directed to solving the same problem of using standard, pre-installed generic drivers, such as human interface device (HID) drivers, to access programs stored on peripheral devices.” Pet. Reply. 3–5; See Ex. 1001, 5:38–40; Ex. 1026 ¶¶ 3, 28. We, thus, are not persuaded by Patent Owner that Mardisk is non-analogous art. slip op. at 16
Patent outcomesUS 11,403,237 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,403,237 - Google LLC v. Mindbasehq, LLCAll claims unpatentablePTAB · Mar 16, 2026 · IPR2021-01252 · APJ Kara L Szpondowski · IPR · Remand
On remand, claims 14–19, 33–40, and 43–46 were held unpatentable as obvious; the Federal Circuit’s affirmed findings leave claims 1–13, 20–32, 41, and 42 unpatentable as well.
RulingsRemand decision- RemandOther
“to both cases vacating and remanding in part and affirming in part our Final Written Decisions. Appeal Dec. With respect to Petitioner’s appeals, the Federal Circuit addressed the “dictionary routine” claims (claims 14–19 and 33–40) and the “normalization” claims (claims 43–46). Appeal Dec. 7–14. For the “dictionary routine” claims, the Federal Circuit vacated and remanded, stating that In sum, as Google contends and we now hold, the “dictionary routine” claims can be practiced by use of an already-created dictionary, and do not also require the automatic creation of a dictionary. The Board needs to consider Google’s evidence and argument by applying this construction of the automatically classifying and storing limitation, and using this understanding to determine whether Conlon may, in fact, render the “dictionary routine” claims obvious (and, relatedly, whether its prior distinctions of Conlon may be immaterial). Appeal Dec. 10–11. For the “normalization” claims, the Federal Circuit also vacated and remanded, stating that our “decision to exclude Google’s rebuttal argument and supplemental declaration is based on a clear factual error,” so on remand we “must include evaluation of the evidence and argument Google provided in reply.” Id. at 13–14. With respect to Patent Owner’s cross-appeals, the Federal Circuit affirmed. Id. at 14–16.” slip op. at 3
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“The Federal Circuit concluded that Petitioner’s construction of “automatically classifying and storing” (as recited in limitation [14.3]), is correct. Appeal Dec. 8. That is, “the ‘dictionary routine’ claims can be practiced by [the] use of an already-created dictionary, and do not also require the automatic creation of a dictionary.” Id. at 10; see also Reply 7 (the limitation is “directed to the use of a dictionary function to automatically look up words and their syntax”); Appeal Dec. 8 (“nothing about the term . . . would inform a person of ordinary skill in the art that automatic ‘creation’ of a database, in addition to the ‘use’ of an already-created database, is a requirement of the dictionary routine claims”); id. (“the plain and ordinary meaning of the claim language is broad enough to include ‘use’”); id. (agreeing with Petitioner that “the specification describes the ‘dictionary routine’ as the act of looking up words already in the database”); id. at 9 (stating that “[i]t is notable, as well, that the specification nowhere describes automatically creating a dictionary; all instances of creating dictionary entries rely, at least in part, on manual data entry by users”). As directed by the Federal Circuit, we will apply this construction in our analysis.8 Id. 8 Patent Owner argues that the Federal Circuit “cherry-picks” and misinterprets the patents’ specifications, and “ignores the clearly contrary specification language.” PO Remand Br. 4–5, 10; id. at 8 (arguing that that the specification clearly set forth the definition of the claim term, and “the Board must accept term definitions . . . above all external definitions”). We do not consider these arguments on the construction of this limitation, because the Federal Circuit has directed us to proceed under its construction of the limitation. We also agree with Petitioner that the Federal Circuit’s claim construction is “foreclosed from further consideration” under its” slip op. at 17
- Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableMotivation foundUnpatentable
“We agree with Petitioner that claim 43 is obvious over the combination of Conlon, Miller, and Fong. The Federal Circuit stated, “[i]n this context, ‘normalization’ generally refers to de-duplicating and simplifying database entries (for instance, combining entries for ‘car’ and ‘automobile’).” Appeal Dec. 4 (cited at Pet. Response Br. 5). This is consistent with the disclosure in the ’433 patent. E.g., Ex. 1001, 16:55– 17:24 (discussing, for example, “recogniz[ing] that the differently named data elements in different structures are actually the same data element . . . is referred to as normalizing the names of the same data elements,” “recogniz[ing] that the same named data elements in different structures are actually different data elements . . . is referred to as normalizing the names of the different data elements,” and “normalizing multiple single data elements”). This is also consistent with how Fong describes “normalization.” Ex. 1029, 76 (The “Function” of “Normaliz[ing] the collection of entities” is to “[r]emove redundancies and detect errors”); see also Ex. 1057 ¶ 226. Patent Owner’s arguments that Fong’s normalization is “different” from the normalization described in the ’433 patent does not persuasively rebut Petitioner’s arguments. As Petitioner points out, Patent Owner does not provide a construction for “normalization,” despite claiming that the term is “defined” in the ’433 patent. Pet. Remand Resp. Br. 6; PO Remand Br. 13. Moreover, although Patent Owner purports to identify differences between the ’433 patent and Fong, the “normalization” applied is expressly recited in limitations [43.1.1], [43.1.2], and [43.2], and the subsequent actions taken on those normalized databases (i.e., comparing and recording) are recited in limitations [43.3]–[43.5]. That is, the “normalization” required by the claim is reflected in the claim language itself, and is broader than argued by Patent Owner. See In re Baxter Travenol Labs., 952 F.2d 388, 391 (Fed. Cir. 1991) (“It is not the function of this court to examine the claims in greater detail than argued by an appellant, looking for nonobvious distinctions over the prior art”). Patent Owner does not explain how these purported “differences” (e.g., that Fong may require the use of “database keys,” “identifiers,” “entities,” or determining ‘non-key attributes’ from key attributes) impacts the claim language, or Petitioner’s showing. See EWP Corp. v. Reliance Universal Inc., 755 F.2d 898, 907 (Fed. Cir. 1985) (A prior art reference “must be considered for everything it teaches by way of technology and is not limited to the particular invention it is describing and attempting to protect”). For the same reasons, as well as those set forth by Petitioner, we are also not persuaded by Patent Owner’s arguments that each DBMS requires a normalization process that is customized for it. Pet. Remand Resp. Br. 6–7. These arguments by Patent Owner also are not commensurate with the scope of the claim language, which does not recite a DBMS, and generally recites “normalizing” or “normalized” without regard to the DBMS. Id. Dr. Jansen provides an example of a database in unnormalized form that is converted into a normalized form, based on Fong’s four conditions, as applied to the claim language. See Reply 31–35; Ex. 1057 ¶¶ 226–261. Therefore, we are not persuaded by Patent Owner’s arguments that Petitioner has not explained how the example maps onto the limitations. PO Remand Resp. Br. 6–12. Patent Owner’s complaint that Dr. Jansen created the graphic in the example does not undermine Petitioner’s showing. E.g., Trial Practice Guide,14 I.G., (“Experts may testify about the teachings of the prior art and how they relate to the patentability of the challenged claims.”). We find Dr. Jansen’s testimony credible and persuasive in explaining why the combination of Conlon and Fong teaches the claim limitations. After considering the properly presented evidence and arguments of the complete record, we determine that Petitioner has shown, by a preponderance of the evidence, that the combination of Conlon, Miller, and Fong teaches the limitations in claim 43, that one of ordinary skill in the art would have been motivated to combine the teachings of Conlon, Miller, and Fong, and that claim 44 would have been obvious over Conlon, Miller, and Fong. 2. Analysis of Dependent Claims 44–46 Claims 44–46 depend, directly or indirectly, from claim 41. We, likewise, determine whether the combination renders obvious claims 44–46, taking into account the arguments made in Petitioner’s Reply Briefs and Dr. Jansen’s Supplemental Rebuttal Declarations. Petitioner contends that dependent claims 44–46, would have been obvious over Conlon, Miller, and Fong, and provides explanation as to how the prior art teaches each claim limitation. Pet. 84–86; Reply 35–39; Pet. Remand Br. 13–14. Patent Owner does not provide further briefing on dependent claims 44–46. 14 Available at https://www.uspto.gov/patents/ptab/trial-practice-guide#step2. Patent Owner did not specifically challenge Petitioner’s contentions as” slip op. at 31
- Strike new argumentNew argument disregardedDecided for petitioner
“Patent Owner’s arguments do not undermine Petitioner’s showing. Patent Owner did not specifically challenge Petitioner’s contentions as to the sufficiency of Conlon’s disclosure for claim 1410 in the Patent Owner Response. In the Sur-replies, Patent Owner argues that the claim requires that at least some relationships are created “automatically,” and “these automatic embodiments . . . are represented in this group of claims.” Sur-reply 9. Along these lines, in the additional briefing Patent Owner argues that Conlon does not teach “automatic,” but merely teaches “semi-automatic.” PO Remand Br. 9–10. The crux of Patent Owner’s argument, however, is that the Federal Circuit did not properly construe the limitation, and ignored certain disclosures in the ’433 (and ’680) patent. Id. at 10–11; see Pet. Remand Resp. Br. 1–4; PO Remand Resp. Br. 4–5. The Federal Circuit held that “the dictionary routine claims can be satisfied by mere use of a lexical database, and do not also require the automatic creation of additional definitions.” Appeal Dec. 10. Moreover, the statements from Conlon that Patent Owner relies upon relate to creating a database, not using the database. See id. As discussed above, on remand we are directed to apply the Federal Circuit’s construction. Patent Owner does not explain 10 As discussed in the original Final Written Decisions, Patent Owner raised several arguments that generally applied to all the claims, challenging, for example, the level of ordinary skill in the art, whether Conlon, Miller, and Beckwith were analogous art, and several general arguments relating to Conlon and the motivation to combine Conlon with a DBMS. See Final Dec. 14–23, 25–27. We were not persuaded by Patent Owner’s arguments; the Federal Circuit affirmed, determining that our findings were supported by substantial evidence. Appeal Dec. 14–16. why Petitioner’s contentions are not persuasive in light of the Federal Circuit’s construction of this limitation. In addition, Patent Owner argues in the Sur-replies that “[c]laims 14– 19 are not disclosed by the proffered prior art” and cites to paragraphs 78–83 of the Ranka Rebuttal Declarations. Sur-reply 10. As discussed in the original Final Written Decisions, Patent Owner’s reliance on six paragraphs of Dr. Ranka’s Rebuttal Declarations is an improper incorporation by reference, as Patent Owner did not discuss that testimony or further elaborate on these arguments in the Sur-replies. 37 C.F.R. § 42.6(a)(3); Cisco Systems, Inc. v. C-Cation Techs., LLC, IPR2014-00454, Paper 12 at 9–10 (PTAB Aug. 29, 2014) (informative); see, e.g., Final Dec. 37–39, 45, 48–50, 52. Therefore, we will not consider arguments that are not made in the Sur-replies, but are instead improperly incorporated by reference to the cited paragraphs in Dr. Ranka’s Rebuttal Declarations. Accordingly, after considering the evidence and arguments of the complete record, we determine that Petitioner has shown, by a preponderance of the evidence, that Conlon teaches limitation [14.3], and that claim 14 would have been obvious over Conlon.” slip op. at 21
Patent outcomesUS 6,665,680 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 6,665,680 - Qualcomm Incorporated v. Cobblestone Wireless, LLCSome claims unpatentablePTAB · Mar 5, 2026 · IPR2024-01336 · APJ Russell E Cass · IPR · Final written decision
Claims 1–4, 6–9, 24, and 25 are unpatentable; claims 10, 13, 14, 17, and 21–23 were not shown unpatentable, principally due to missing limitations or insufficient motivation to combine.
RulingsFinal written decision- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“information” should be given its plain and ordinary meaning as “data,” and that Patent Owner’s narrower construction of “first information” and “second information” lacks sufficient support in the intrinsic record. We agree with Petitioner that the ’802 patent Specification defines “information” as data when it uses the phrase “information (i.e., data).” See Ex. 1001, 5:60–62 (“Information (i.e., data) to be transmitted may be received in a baseband digital system 250, such as a wireless digital baseband processor.” (emphasis added)), 11:30–32 (“In this example, the signals 911 and 912 carry the same information (data).” (emphasis added)). As the Federal Circuit has explained, a “specification’s use of ‘i.e.’ signals an intent to define the word to which it refers.” Edwards Lifesciences LLC v. Cook Inc., 582 F.3d 1322, 1334 (Fed. Cir. 2009). slip op. at 13
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableNot shown unpatentableMixed
“argument based on Fernandez alone, we find that Petitioner has not provided a sufficient evidentiary basis to support a motivation to remove the amplification from each of Fernandez’s signal generators 10A-10E and add a single power amplifier instead. See Pet. 76–77 Ex. 1003 ¶ 235. Petitioner’s only rationale for this modification to Fernandez is that “[a] single amplifier has several advantages compared to multiple amplifiers, including lower complexity, a single (vs. multiple) potential point of failure, and lower cost,” and that one of ordinary skill “would have found a single amplifier to be a simple matter of design preference.” Pet. 76–77. Dr. Almeroth simply repeats these cursory allegations without providing any further explanation or evidentiary support. Ex. 1003 ¶ 235. Moreover, Dr. Cooklev provides credible testimony that replacing Fernandez’s amplification in signal generators 10A–10E with a single amplifier would not necessarily have the advantages that Petitioner suggests. See Ex. 2013 ¶¶ 99, 104–105. For example, Dr. Cooklev testifies that a single amplifier would need to have a wider bandwidth than the multiple amplifiers used in Fernandez, which could cause potential stability issues. Id. ¶ 105. According to Dr. Cooklev, this wider bandwidth would require more circuit elements, and thus would not provide the reduction in space usage and power consumption that Petitioner asserts. Id. According to Dr. Cooklev, Montojo also points to several “substantial, and potentially impractical, drawbacks” of using a single amplifier for multiple signal generators, including power constraints imposed by spectral emission requirements and on-board battery capacity. Id. ¶ 104 (citing Ex. 1006 ¶¶ 7– 8). In light of this testimony, which we find credible, Petitioner has failed to provide sufficient explanation or evidence to support its assertion that one of ordinary skill would have found it obvious to replace the multiple amplifiers in Fernandez’s signal generators with a single amplifier.” slip op. at 65
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentable
“argument based on Fernandez alone, we find that Petitioner has not provided a sufficient evidentiary basis to support a motivation to remove the amplification from each of Fernandez’s signal generators 10A-10E and add a single power amplifier instead. See Pet. 76–77 Ex. 1003 ¶ 235. Petitioner’s only rationale for this modification to Fernandez is that “[a] single amplifier has several advantages compared to multiple amplifiers, including lower complexity, a single (vs. multiple) potential point of failure, and lower cost,” and that one of ordinary skill “would have found a single amplifier to be a simple matter of design preference.” Pet. 76–77. Dr. Almeroth simply repeats these cursory allegations without providing any further explanation or evidentiary support. Ex. 1003 ¶ 235. Moreover, Dr. Cooklev provides credible testimony that replacing Fernandez’s amplification in signal generators 10A–10E with a single amplifier would not necessarily have the advantages that Petitioner suggests. See Ex. 2013 ¶¶ 99, 104–105. For example, Dr. Cooklev testifies that a single amplifier would need to have a wider bandwidth than the multiple amplifiers used in Fernandez, which could cause potential stability issues. Id. ¶ 105. According to Dr. Cooklev, this wider bandwidth would require more circuit elements, and thus would not provide the reduction in space usage and power consumption that Petitioner asserts. Id. According to Dr. Cooklev, Montojo also points to several “substantial, and potentially impractical, drawbacks” of using a single amplifier for multiple signal generators, including power constraints imposed by spectral emission requirements and on-board battery capacity. Id. ¶ 104 (citing Ex. 1006 ¶¶ 7– 8). In light of this testimony, which we find credible, Petitioner has failed to provide sufficient explanation or evidence to support its assertion that one of ordinary skill would have found it obvious to replace the multiple amplifiers in Fernandez’s signal generators with a single amplifier.” slip op. at 65
- Expert testimonyPatent owner expert creditedPetitioner expert discountedOther
“We find credible and agree with Dr. Cooklev’s testimony that the predistortion signals from tables 17-1 and 17-2 “are cancelled out by Suzuki’s amplifier” 28. Ex. 2013 ¶ 50. Dr. Cooklev supports his opinion by referring to paragraph 1 of Suzuki, which states that Suzuki’s invention is directed to “a multi-band lookup table type predistorter” (such as the one implemented using lookup tables 17-1 and 17-2 in Figure 6) that “compensates for a distortion of a power amplifier.” Ex. 2013 ¶ 54; Ex. 1004 ¶ 1. Dr. Cooklev’s opinion is also supported by paragraph 3 of Suzuki, which explains that a conventional digital predistorter uses a lookup table “for linearizing non-linear characteristics of an amplifier.” Ex. 1004 ¶ 3; Ex. 2013 ¶ 54. Dr. Cooklev further supports his opinion by relying on Suzuki’s disclosure in paragraph 46 that power amplifier 28 is “subject to distortion compensation” by the predistorter, and that distortion components in the signal output by the amplifier are canceled by “distortion compensation data [that] are read out from the lookup tables 17-1 and 17-2 and provided to the adders 13-1 and 13-2, respectively.” Ex. 1004 ¶ 46; Ex. 2013 ¶ 54. And, Dr. Cooklev’s opinion is supported by Suzuki’s disclosure in paragraph 47 that the distortion compensation added by adders 13-1 and 13-2 add the distortion compensation data from lookup tables 17-1 and 17-2 “to perform distortion compensation (addition of predistortion)” to “signals to be transmitted.” Ex. 1004 ¶ 47; Ex. 2013 ¶ 54. Petitioner agrees that the distortion compensation data from lookup tables 17-1 and 17-2 “are added to the respective frequency band from” input signal ST “in order to predistort the output signal, which is then transmitted,” and does not dispute that the distortion compensation data from lookup tables 17-1 and 17-2 is ultimately cancelled out by the distortion created by amplifier 28. Pet. Reply 8. In light of the above evidence, we agree with Patent Owner that Suzuki’s distortion components from lookup tables 17-1 and 17-2 in Figure 6 (which Petitioner relies on for the first and second digital signals in limitations 10a and 10b) are cancelled out by the distortion created by power amplifier 28 before the signal is ultimately transmitted. We agree with Petitioner that these first and second digital signals include data in the form of distortion compensation data. However, because these signals are cancelled by the distortion from amplifier 28 before transmission, the data from these signals is never transmitted. Thus, the first and second digital signals identified by Petitioner (the distortion compensation data from lookup tables 17-1 and 17-2) do not comprise data “to be transmitted,” as limitations 10a and 10b require.” slip op. at 35
Patent outcomesUS 7,924,802 mixedClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 7,924,802 - Reolink Innovation Inc. / Shenzhen Reolink Technology Co., Ltd. v. Throughtek Co., Ltd.All claims unpatentablePTAB · Jan 23, 2026 · IPR2024-01192 · APJ Michael J Strauss · IPR · Final written decision
Claims 1–10 and 16 are unpatentable as obvious over the asserted combinations of the Lorex Manual or Lorex Video with the identified references.
RulingsFinal written decision- Novelty / Anticipation (§102) › Priority / effective filing date / continuation supportPriority date awardedDecided for petitioner
“Patent Owner does not dispute any of Petitioner’s contentions as to the effective filing date, stating in agreement with Petitioner’s asserted Effective Filing Date of the Challenged Claims that “[t]he ’916 Patent claims a priority of a provisional application 61/924,240 filed on January 7, 2014.” PO Resp. 8. Given that the parties are in agreement on the January 7, 2014, effective filing date, we similarly use January 7, 2014, as the effective filing date of the challenged claims for purposes of this Decision.” slip op. at 4
- Skill levelSkill level petitioner adoptedDecided for petitioner
“II. ANALYSIS A. Level of Ordinary Skill in the Art Relying on the testimony of Vlad Kardashov, Petitioner proposes that a person of ordinary skill in the art at the time of the invention of the ’916 patent “would have had a bachelor’s degree in electrical engineering and two 7 US 2012/0198040 A1, published August 2, 2012 (Ex. 1011, “Kuo”). 8 The subject ’916 patent claims priority to Kuo as a continuation-in-part of that earlier filed application. Ex. 1001, code (63). 9 Lorex Technology Inc., “How to set up remote access for DVR using - Lorex Stratus Connectivity” (June 18, 2013), available at https://www. youtube.com/watch?v=fMPRi9WFuTM (Ex. 1012, the “Lorex Video”). 10 US 2012/0113265 A1, published May 10, 2012 (Ex. 1013, “Galvin”). years of work experience with network and communication technologies.” Pet. 8 (citing Ex. 1003 ¶¶ 12–14). Patent Owner does not contest Petitioner’s proposal or provide a proposal of its own. On the complete record, we adopt Petitioner’s description of the level of ordinary skill in the art, as it is consistent with the technology described in the ’916 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner asserts that “no claim elements need a formal construction for purposes of resolving controversies in this proceeding.” Pet. 9 (citing Ex. 1003 ¶¶ 43–44; Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011), Google Inc. v. Intellectual Ventures II LLC, 701 Fed. Appx. 946, 956 (Fed. Cir. 2017)). Petitioner states “[a]ll claim terms should be construed according to the Phillips standard.” Id. (citing Phillips, 415 F.3d at 1303; 37 C.F.R. § 42.100). Patent Owner presents no proposed claim constructions. We determine that we need not expressly construe any claim terms to resolve the parties’ disputes on the current record. See 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)).” slip op. at 9
- Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityReference is prior artPriority date awardedDecided for petitioner
“that Patent Owner fails to demonstrate that the Lorex Manual was based on a disclosure made by the inventor or joint inventor or by another who obtained the subject matter disclosed directly or indirectly from the inventor or a joint inventor. The Lorex Manual is relied on under Ground 1A, exclusively or in the alternative to or in combination with Kim, for all claim elements. Pet. 9– 31. Patent Owner fails to demonstrate that this subject matter was disclosed to Lorex by ThroughTek, much less by one of the inventors of the ’916 Patent.” slip op. at 22
Patent outcomesUS 9,774,916 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 9,774,916 - Ericsson Inc. / Nokia Of America Corporation v. XR Communications LLCAll claims unpatentablePTAB · Nov 25, 2025 · IPR2024-00868 · APJ Kara L Szpondowski · IPR · Final written decision
Claims 1, 2, 4–6, 9–11, 13–15, and 18–20 are unpatentable as obvious over Trigui; claims 4–6, 13–15, and 18 are also unpatentable over Trigui and Rudrapatna.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Patent Owner does not challenge Petitioner’s characterization of the level of ordinary skill in the art, or provide an alternative level of ordinary skill in the art. PO Resp. 9. In the Institution Decision, we adopted Petitioner’s proposed level of ordinary skill in the art, which was also undisputed by Patent Owner at that stage of the proceeding. Inst. Dec. 11–12. Because nothing in the record establishes that our preliminary finding in the Institution Decision was incorrect, and because there is no dispute, we maintain our adoption of Petitioner’s proposed level of ordinary skill in the art.” slip op. at 12
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“C. Claim Construction Petitioner contends “[n]o specific construction of any term is required,” and Petitioner has applied the “ordinary and customary meaning” of the claim terms. Pet. 13–14. Patent Owner states that, “[f]or purposes of this proceeding, Patent Owner agrees that no formal claim construction is necessary.” PO Resp. 9. Patent Owner provides the Board with the district court’s constructions in the related litigation. Id. (citing 2007, 39).4 4 The Petition in this case was filed on May 8, 2024. In the related litigation, Patent Owner’s opening brief on claim construction was filed on July 15, 2024, defendants’ responsive brief on claim construction was filed on this Decision, we need not expressly construe any claim terms to resolve the parties’ disputes. 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)). Accordingly, to the extent necessary, we apply the district court’s constructions and the plain and ordinary meaning of the claim terms. To the extent that the scope of any particular claim term requires discussion, we provide it in our assessment of the challenges.” slip op. at 12
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“Figures 6 and 10 show multiples of the system of Figure 2A. Id.; see also id. ¶ 81 (describing Figure 6) ¶ 85 (describing Figure 10). We find persuasive Petitioner’s arguments that Trigui’s arrays may consist of “subarrays.” See Pet. 24; Reply 9. For example, Trigui describes that “[t]he antenna arrays 256 may consist of sub-arrays where the antenna elements of each sub-array are combined passively to achieve a predefined pattern.” Ex. 1004 ¶ 50. To that end, Figure 6 shows one antenna array that consists of two Passive Antenna Sub-arrays (i.e., the plurality of antenna elements), and Figure 10 shows two antenna arrays that each consist of two Passive Antenna Sub-arrays (i.e., the plurality of antenna elements). See Pet. 28–32; Reply 9–11. Given this disclosure in Trigui, we do not find persuasive Patent Owner’s arguments that Figure 6 does not show a single antenna array, or that Figure 10 does not show two antenna arrays. PO Resp. 17–18. Patent Owner also argues that a person of ordinary skill in the art would understand that Trigui’s sub-arrays are not intended to be combined. PO Resp. 18. This argument contradicts Trigui’s disclosure, which shows multiples of the hardware of Figure 2A in Figures 6 and 10, and encourages multiple operator sharing of passive antenna arrays and transceivers. See, e.g., Reply 4 (describing Trigui as “providing building blocks that should be combined to understand Trigui’s full teachings”); Ex. 1004 ¶¶ 48, 68. Trigui even states as much: Although FIG 2A illustrates only a single MIMO branch DIAA, the present invention contemplates the use of multiple MIMO branches (as will be illustrated below with reference to FIGS. 6–11) . . . Similarly, I/Q signals 215 from any of the modems, as well as the beamforming weights 214, can be sent to other MIMO branches. Patent Owner’s argument that “Trigui does not teach any relationship between the number of beams and the number of MIMO transceivers” is not well developed and is unpersuasive in light of Petitioner’s showing. Petitioner has demonstrated that Trigui’s Figure 6 depicts one antenna array with two bi-directional beams. Pet. 27–28. Petitioner has further demonstrated that Trigui’s Figure 10 depicts two antenna arrays, i.e., where m=2, where each array comprises a beamformer configured to produce n different bi-directional beams, i.e., where n=2. Id. at 28–29. Petitioner’s annotated Figure 10 is reproduced below: Id. at 29. Petitioner’s annotated Figure 10 shows two copies of the arrangement shown in Figure 6, where Petitioner has identified in red the two antenna arrays, and identified in blue the beams. That is, Trigui’s Figure 10 shows two antenna arrays that each produce two beams. Figures 3 and 4 of Trigui (PO Resp. 16–17) do not address Petitioner’s contentions. See Reply 6–7. Petitioner relies on Figures 4A and 4B to support that “[e]ach of Trigui’s arrays can produce multiple beams.” Pet. 26; Reply 7. Dr. Cooklev agrees. PO Resp. 16 (citing Ex. 2003 ¶ 91). However, as described above, Petitioner relies on Figure 6 to show “n” different bidirectional beams where n=2. Pet. 27. Petitioner does not rely on Figures 3 and 4 to teach the “n” number of beams. See Reply 7. Accordingly, we do not agree with Patent Owner’s argument that the Petition provides no evidence for the “n different bidirectional beams.” See Sur-reply 11–12; see Pet. 27 (citing Ex. 1004 ¶¶ 9, 14, 74, 77, 81; Ex. 1003 ¶¶ 189, 192, 193).” slip op. at 18
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“Trigui explicitly discloses that its system may have multiple modems. See Pet. 38; Reply 15. For example, Figure 2A shows Modem A, Modem B, and Modem C for a single MIMO branch. Ex. 1004 Fig. 2A; see also id. ¶37 (“one or more modems 204, such as, for example, baseband modules of cellular base stations”) ¶ 41 (“I/Q signals 215 from any of the modems . . . can be sent to other MIMO branches”); see Pet. 34. We find persuasive Petitioner’s explanation, supported by testimony from Dr. Negus, that “Trigui teaches use cases in which two separate wireless network operators would share certain tower [equipment,] such as the antenna arrays, but each wireless network operator would have its own baseband unit (i.e., modems A for the first operator and B for the second operator).” Pet. 33 (citing Ex. 1003 ¶¶ 226–232); e.g., Ex. 1004 ¶ 48 (stating that “the present invention . . . enable[s] multiple operator sharing of a passive antenna array, transceivers, and the total available power of the DIAA”); id. (“[S]plitting resources between the multiple operators is flexible and should be done on the basis of the individual operator needs”); ¶ 2 (“enabling a versatile solution for sharing antenna elements and active electronics between multiple operators servicing the same geographic area”); see also Pet. 38–41 (providing further explanation that one modem would be implemented for each operator); Reply 18–21. Patent Owner agrees that the second modem would be for a different operator. PO Resp. 20 (stating that “[E]ven if a second modem is added, it would be for a different operator”).5 Therefore, we are persuaded 5 In the Sur-reply, Patent Owner argues the opposite; that the operators would not have separate modems. Sur-reply 4. We rely on Patent Owner’s modems that share the two DIAA arrays in Figure 10. Pet. 42; Reply 18; In re Applied Materials, Inc., 692 F.3d 1289, 1298 (Fed. Cir. 2012) (“A reference must be considered for everything that it teaches, not simply the described invention or a preferred embodiment.”). Thus, we find that Petitioner’s proposed modification for Figure 10 is derived from Trigui’s disclosures, not through hindsight. See In re McLaughlin, 443 F.3d 1392, 1395 (CCPA 1971) (“Any judgment on obviousness is in a sense necessarily a reconstruction based on hindsight reasoning, but so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made and does not include knowledge gleaned only from applicant’s disclosure, such a reconstruction is proper”).” slip op. at 26
Patent outcomesUS 8,737,511 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,737,511 - Apple Inc. v. Proxense, LLCAll claims unpatentablePTAB · Nov 12, 2025 · IPR2024-01399 · APJ Thu A Dang · IPR · Final written decision
Claims 1–6, 8–15, and 17–20 are unpatentable under § 103, based on Buer alone or in the combinations listed.
RulingsFinal written decision- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“1 Apple Inc. filed a motion for joinder and a petition in IPR2024-01399, which were granted, and, therefore, Apple Inc. has been joined as petitioner in this proceeding. We also granted a Joint Motion to Terminate Inter Partes Review Proceeding as to the other petitioner, leaving Apple Inc. as the sole petitioner.” slip op. at 1
- Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)§112(f) does not applyDecided for petitioner
“Here, as Petitioner points out, “[n]one of the elements of the Challenged Claims . . . use the word ‘means,’” similar to the challenged claims in the previous related proceedings. Pet. Reply 2–3; see also IPR2024-00405, Ex. 1001, 22:43–60; IPR2024-00407, Ex. 1001, 22:36–49; IPR2024-00573, Ex. 1001, 21:51–65. As the Federal Circuit stated, when a disputed claim limitation does not employ “means for” language, the presumption is that each of the terms conveys sufficiently definite structure or act and, thus, is not subject to § 112 ¶ 6. See Dyfan, 28 F.4th at 1367. Based on the record before us, this presumption that each of the terms is not subject to § 112 ¶ 6 is not overcome.” slip op. at 17
- Prior constructionPrior construction adoptedDecided for patent owner
“invoke 35 U.S.C. § 112 ¶ 6. See PO Resp. 4; Pet. Reply 2; PO Sur-reply 8. However, we addressed similar arguments with respect to this issue in previous related proceedings. See IPR2024-00405, Paper 24 at 8–25; IPR2024-00407, Paper 25 at 8–26; IPR2024-00573, Paper 27 at 8–29. In fact, during Oral Argument in this proceeding, Patent Owner acknowledged that “this panel construed the claims at issue in [previous proceedings,] IPR2024-573 and 2024-407.” Tr. 20:3–5. In particular, Patent Owner acknowledged that “the Board would rely on and import the construction from those IPRs, . . . 2024-407 and ’573 for the sake of consistent office determination.” Id. at 20:9–11. That is, Patent Owner agreed that the Board should use the prior constructions for the same claim terms at issue in this proceeding. Id. at 26:12–16 (“JUDGE MCKONE: -- it sounds like everybody agrees, that we should use the prior claim constructions from [the] other proceedings . . . Do you agree? MR. HECHT: -- if the Board agrees, absolutely.”). Petitioner also agreed that the Board should use the prior constructions. See id. at 31:23–32:3 (“JUDGE MCKONE: And so I assume you want us to use the same claim construction in this case as the previous case[s]; is that correct? MR WOO: That is correct, Your Honor.”). We agree with the parties that, for the sake of consistency, we apply our claim constructions from the previous proceedings. Tr. 20:22–25. As set forth in the previous related proceedings, we determined that the claims do not invoke 35 U.S.C. § 112 ¶ 6. See IPR2024-00405, Paper 24 at 8–25; IPR2024-00407, Paper 25 at 8–26; IPR2024-00573, Paper 27 at 8–29. Thus, for consistency, and for the reasons given in the previous related proceedings, in this proceeding, we also determine that the claims do not invoke 35 U.S.C. § 112 ¶ 6, as discussed below.” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“We find Patent Owner’s arguments unavailing. In particular, we disagree with Patent Owner’s contention that the District Court provided a construction for “one or more of the integrated RDC and integrated PDK enabling one or more of an application, a function, and a service,” as recited in claim 1. Although Patent Owner points to the District Court’s Memorandum in Support of Claim Construction Order (id. at 32 (citing Ex. 2002, 26)) to support its contention that the District Court construed the term “enabled,” as we determined in the Decision to Institute, this portion of the District Court’s Memorandum merely discusses that “hybrid device” is not indefinite, and discusses exemplary operations of the “hybrid device” from which a POSITA “could reasonably ascertain the scope of the claim.” See Dec. Inst. 9. As we explained, a determination of whether a term is indefinite is not the same thing as construing a claim term. Id. Thus, as we previously explained, by determining that “hybrid device” is not indefinite, the District Court did not construe the term “enabled.” Id.; see also Ex. 2002, 26. Accordingly, nothing in the Memorandum provides a construction of “enabled” as Patent Owner contends. Id. Thus, we find unavailing Patent Owner’s contention that Buer does not disclose the “enabled” limitation because, in Buer, “no key is provided in exchange for the information.” PO Resp. 33. That is, we decline to adopt Patent Owner’s proposed construction that an application, function or service is “enabled” by a PDK “when it receives information from a PDK in exchange for an access key.” Id. at 32. Here, as Petitioner points out, Buer discloses an authentication component for providing credentials to a service provider to authenticate access to secured services, wherein the authentication component generates an RF signal providing the necessary authentication information to a service provider. Pet. 45; see Ex. 1005 ¶¶ 152, 174. Buer further discloses a mobile device with an RFID client to authenticate a user to another processing system, the mobile device transmitting an enablement signal to a computer with a point-of-sale device. Pet. 47; see Ex. 1005 ¶¶ 192–195. We find availing Petitioner’s contention that Buer’s authentication component “enables” a wide variety of applications, functions, or services. Pet. 56. Petitioner’s contention is supported by Dr. Wolfe’s testimony and is consistent with the teachings of Buer. See Ex. 1003 ¶ 229. Based on the complete record presented, we determine that Petitioner has persuasively shown that Buer teaches “one or more of the integrated RDC and integrated PDK enabling one or more of an application, a function, and a service on one or more of the hybrid device and a device associated with the external RDC,” as recited in claim 1.” slip op. at 39
Patent outcomesUS 8,646,042 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,646,042
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.