• Yealink (USA) Network Technology Co., Ltd. / Yealink Network Technology Co., Ltd. v. Barco NVNo claims unpatentable
  PTAB · 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 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · Graham
  Patents in suitUS 11,966,347
• Meta Platforms, Inc. / ROKU, Inc. et al. v. Almondnet, Inc. And Intent Iq, LLCNo claims unpatentable
  PTAB · Feb 19, 2025 · IPR2024-00666 · APJ Stacey G White · IPR · Final written decision

  Claims 1–4 and 6–23 were not shown unpatentable because the asserted combinations did not establish the required determination that access occurred during a predetermined period.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner asserts that a person of ordinary skill in the art “would have possessed a bachelor’s degree in electrical engineering or computer science, and two years of work experience in the field of network-based computer systems, such as systems for sending and receiving information over local networks and wide area networks (such as the Internet or World Wide Web).” Pet. 5 (citing Ex. 1002 ¶¶ 10–14). Patent Owner does not challenge Petitioner’s description of the level of ordinary skill in the art. See Ex. 2001 ¶ 26 (adopting Petitioner’s proposed level of skill in the art for the purposes of this proceeding). We are persuaded that Petitioner’s description is consistent with the prior art and patent specification. Accordingly, we adopt Petitioner’s description.” slip op. at 8

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

    “Petitioner “does not believe claim construction is necessary at this time.” Pet. 7. “Patent Owner does not contend that any terms in the challenged claims require express construction for purposes of evaluating the Petition’s invalidity grounds.” PO Resp. 7. We determine that no claim terms require express construction for purposes of this Decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting 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 9

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Patents / published applications (effective date, provisional support)Reference is prior artDecided for petitioner

    “date of Provisional Application No. 60/858,204 (Ex. 1004, “’204 Provisional”), and is prior art to the ’878 Patent under pre-AIA 35 U.S.C. § 102(e). Pet. 9. Petitioner asserts that the ’204 Provisional provides support for the disclosure of Baig and provides § 112 support for at least one claim in Baig. Id. Petitioner asserts that there are no material differences between Baig and the ’204 Provisional. Id. at 10 (citing Ex. 1002 ¶ 43 (citing Ex. 1005 (redline comparison of Ex. 1003 and Ex. 1004))). Petitioner further contends that the ’204 Provisional includes 17 claims that are identical to the claims in Baig, and, therefore, provides written description support for the corresponding claims in Baig. Id. Petitioner also asserts the ’204 Provisional provides enablement. Id. Patent Owner has not challenged the status of Baig as prior art. See PO Resp. Based on our review of the complete record, we find that Petitioner has shown sufficiently that Baig is entitled to the earlier effective filing date of the ’204 Provisional Application.” slip op. at 12

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable

    “Patent Owner that the plain language of the claim requires there to be a determination that devices accessed the LAN during the predetermined period of time. The claim language recites that the determining of limitation (a) (which recites the determination of an association between the identifiers) is done using the stored association-detection information (which is alleged to be the cookies and session table of the cited art) “to determine” that the mobile devices have separately accessed the internet through a LAN “during a predetermined period of time.” See Ex. 1001, 24:29–49. Thus, we read this language to require that a determination be made that the required access occurred during a predetermined period of time. This reading of the claim language is accord with the opinion expressed by Petitioner’s expert, Mr. Schmandt, at his deposition.” slip op. at 17

  Patent outcomesUS 10,715,878 not shown unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Graham
  Patents in suitUS 10,715,878
• Meta Platforms, Inc. / ROKU, Inc. et al. v. Almondnet, Inc. And Intent Iq, LLCNo claims unpatentable
  PTAB · Feb 19, 2025 · IPR2024-00701 · APJ Stacey G White · IPR · Final written decision

  Claims 1–4 and 6–23 were not shown unpatentable because the prior-art combinations did not establish a determination that devices accessed the Internet during a predetermined period.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner asserts that a person of ordinary skill in the art “would have possessed a bachelor’s degree in electrical engineering or computer science, and two years of work experience in the field of network-based computer systems, such as systems for sending and receiving information over local networks and wide area networks (such as the Internet or World Wide Web).” Pet. 5 (citing Ex. 1002 ¶¶ 10–14). Patent Owner does not challenge Petitioner’s description of the level of ordinary skill in the art. See Ex. 2001 ¶ 26 (adopting Petitioner’s proposed level of skill in the art for the purposes of this proceeding). We are persuaded that Petitioner’s description is consistent with the prior art and patent specification. Accordingly, we adopt Petitioner’s description.” slip op. at 8

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

    “Petitioner “does not believe claim construction is necessary at this time.” Pet. 7. “Patent Owner does not contend that any terms in the challenged claims require express construction for purposes of evaluating the Petition’s invalidity grounds.” PO Resp. 7. We determine that no claim terms require express construction for purposes of this Decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting 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 9

  • Novelty / Anticipation (§102) › Priority / effective filing date / continuation supportReference is prior artDecided for petitioner

    “date of Provisional Application No. 60/858,204 (Ex. 1004, “’204 Provisional”), and is prior art to the ’878 Patent under pre-AIA 35 U.S.C. § 102(e). Pet. 9. Petitioner asserts that the ’204 Provisional provides support for the disclosure of Baig and provides § 112 support for at least one claim in Baig. Id. Petitioner asserts that there are no material differences between Baig and the ’204 Provisional. Id. at 10 (citing Ex. 1002 ¶ 43 (citing Ex. 1005 (redline comparison of Ex. 1003 and Ex. 1004))). Petitioner further contends that the ’204 Provisional includes 17 claims that are identical to the claims in Baig, and, therefore, provides written description support for the corresponding claims in Baig. Id. Petitioner also asserts the ’204 Provisional provides enablement. Id. Patent Owner has not challenged the status of Baig as prior art. See PO Resp. Based on our review of the complete record, we find that Petitioner has shown sufficiently that Baig is entitled to the earlier effective filing date of the ’204 Provisional Application.” slip op. at 12

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable

    “Patent Owner that the plain language of the claim requires there to be a determination that devices accessed the LAN during the predetermined period of time. The claim language recites that the determining of limitation (a) (which recites the determination of an association between the identifiers) is done using the stored association-detection information (which is alleged to be the cookies and session table of the cited art) “to determine” that the mobile devices have separately accessed the internet through a LAN “during a predetermined period of time.” See Ex. 1001, 24:29–49. Thus, we read this language to require that a determination be made that the required access occurred during a predetermined period of time. This reading of the claim language is accord with the opinion expressed by Petitioner’s expert, Mr. Schmandt, at his deposition. Q So is it your opinion that the – the limitation 1B requires that the system determines whether or not the accesses by the -- the two electronic devices occurred within a predetermined period of time? A Yes.” slip op. at 17

  Patent outcomesUS 10,715,878 not shown unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Graham
  Patents in suitUS 10,715,878
• Meta Platforms, Inc. / ROKU, Inc. et al. v. Intent Iq, LLCNo claims unpatentable
  PTAB · Feb 19, 2025 · IPR2023-01281 · APJ Stacey G White · IPR · Final written decision

  Claims 1–4 and 6–23 were not shown unpatentable because the cited combinations did not establish a determination that devices accessed the Internet during a predetermined period.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “we consider the level of ordinary skill in the pertinent art at critical time. Graham v. John Deere Co. of Kan. City, 383 U.S. 1, 17 (1966). The resolution of this question is important because it allows us to “maintain[] objectivity in the obviousness inquiry.” Ryko Mfg. Co. v. Nu–Star, Inc., 950 F.2d 714, 718 (Fed. Cir. 1991). In assessing the level of ordinary skill in the art, various factors may be considered, including the “type of problems encountered in the art; prior art solutions to those problems; rapidity with which innovations are made; sophistication of the technology; and educational level of active workers in the field.” In re GPAC, Inc., 57 F.3d 3 U.S. Pat. Pub. 2008/0113674 A1, published May 15, 2008 (Ex. 1003, “Baig”). 4 U.S. Pat. Pub. 2004/0128547 A1, published July 1, 2004 (Ex. 1006, “Laidlaw”). 5 U.S. Pat. No. 6,427,170 B1, issued July 30, 2002 (Ex. 1007, “Sitaraman”). 6 Harley Hahn, The Internet Complete Reference (2d ed. 1996) (Ex. 1008, “Hahn”). 7 U.S. Pat. No. 7,730,030 B1, issued June 1, 2010 (Ex. 1009, “Xu”). 8 U.S. Pat. Pub. 2006/0282328 A1, published Dec. 14, 2006 (Ex. 1010, “Gerace”). 1573, 1579 (Fed. Cir. 1995). Generally, it is easier to establish obviousness under a higher level of ordinary skill in the art. Innovention Toys, LLC v. MGA Entm’t, Inc., 637 F.3d 1314, 1323 (Fed. Cir. 2011) (“A less sophisticated level of skill generally favors a determination of nonobviousness . . . while a higher level of skill favors the reverse.”). Petitioner asserts that a person of ordinary skill in the art “would have possessed a bachelor’s degree in electrical engineering or computer science, and two years of work experience in the field of network-based computer systems, such as systems for sending and receiving information over local networks and wide area networks (such as the Internet or World Wide Web).” Pet. 5 (citing Ex. 1002 ¶¶ 10–14). Patent Owner does not challenge Petitioner’s description of the level of ordinary skill in the art. See Ex. 2001 ¶ 26 (adopting Petitioner’s proposed level of skill in the art for the purposes of this proceeding). We are persuaded that Petitioner’s description is consistent with the prior art and patent specification. Accordingly, we adopt Petitioner’s description.” slip op. at 7

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

    “using the same claim construction standard that would be used to construe the claim in a civil action under 35 U.S.C. § 282(b). 37 C.F.R. 42.100(b) (2023). Our rule adopts the same claim construction standard used by Article III federal courts, which follow Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc), and its progeny. Under this standard, the words of a claim are generally given their “ordinary and customary meaning,” which is the meaning the term would have to a person of ordinary skill at the time of the invention, in the context of the entire patent including the specification. See Phillips, 415 F.3d at 1312–13. Petitioner “does not believe claim construction is necessary at this time.” Pet. 7. “Patent Owner does not contend that any terms in the challenged claims require express construction for purposes of evaluating the Petition’s invalidity grounds.” PO Resp. 7. We determine that no claim terms require express construction for purposes of this Decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting 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 8

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable

    “We are persuaded by Patent Owner’s arguments. First, we agree with Patent Owner that the plain language of the claim requires there to be a determination that devices accessed the LAN during the predetermined period of time. The claim language recites that the determining of limitation (a) (which recites the determination of an association between the identifiers) is done using the stored association-detection information (which is alleged to be the cookies and session table of the cited art) “to determine” that the mobile devices have separately accessed the internet through a LAN “during a predetermined period of time.” See Ex. 1001, 24:29–49. Thus, we read this language to require that a determination be made that the required access occurred during a predetermined period of time. This reading of the claim language is accord with the opinion expressed by Petitioner’s expert, Mr. Schmandt, at his deposition.” slip op. at 17

  Patent outcomesUS 10,715,878 not shown unpatentable
  Claim construction§ 103 obviousnesscites Graham
  Patents in suitUS 10,715,878
• Samsung Electronics Co., Ltd. v. G+ Communications, LLCNo claims unpatentable
  PTAB · May 31, 2024 · IPR2023-00441 · APJ Gregg I Anderson · IPR · Final written decision

  Claims 1–15 and 17–18 were not shown unpatentable because the prior art did not disclose a “pre-set UE number” under the adopted construction.

  RulingsFinal written decision

  • Prior constructionPrior construction adoptedDecided for patent owner

    “We are not persuaded to maintain our preliminary construction. Indeed, as already noted, Petitioner does not argue for the preliminary construction. Neither does Petitioner question the validity of the reasons given for the District Court’s construction. Rather, Petitioner repeats its position that it “takes no position on the District Court’s construction” and Petitioner does not have any reason “as to why that construction is wrong or right.” Tr. 18:24–19:6. We do not see any reason to construe “pre-set UE number” contrary to what the District Court has determined. Indeed, we find the District Court’s analysis of the issue highly persuasive and adopt it as our own. And Petitioner has not provided any argument regarding construction of the term, simply taking no position on its correctness.” slip op. at 12

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

    “Petitioner has forfeited the indefiniteness argument. Regardless, we are given no reason to find construction of the two means-plus function terms impossible given the District Court determination. We agree that the scope of the terms is based on a means-plus function analysis. We are not persuaded that structure is not sufficiently described.” slip op. at 14

  • Strike new argumentNew argument disregardedDecided for patent owner

    “Patent Owner argues that this argument was not presented in the Petition and is too late and/or incorrect. Sur-reply 5. We agree with Patent Owner. Neither Patent Owner nor the Board were given any notice of this argument in the Petition. Regardless, we find no merit in Petitioner’s argument. Fundamentally, our jurisdiction regarding patentability is limited to Sections 102 and 103 of the Patent Act. 35 U.S.C. § 311(b). We do not find that claim 18 is so indefinite that a patentability determination is impossible. See Intel Corp. v. Qualcomm Inc., 21 F.4th 802, 812–813 (Fed. Circ. 2021) (claim construction obligation “does not mean that the Board must reach a determination of the patentability of a claim on the presented prior-art grounds if such a determination is rendered impossible because of the indefiniteness of an essential claim limitation.”). Indeed, the District Court determined that the corresponding structure is a processor programmed to either (1) descramble a Cyclic Redundancy Check (CRC) of Downlink Control Information (DCI) for scheduling the RAR according to a pre-set RA-RNTI or an RA-RNTI corresponding to the preamble, and receive the RAR, the RAR including at least one TCRNTI and/or at least one Uplink (UL) grant. Ex. 2008, 23 (quoting Ex. 1001, 2:66–3:4). (2) determine corresponding RA-RNTIs according to respective IDs and/or preambles, descramble a CRC of DCI for scheduling the RAR according to the corresponding RA-RNTIs, and receive corresponding RARs, the RAR including a TCRNTI and/or a UL grant allocated to the first UE or second UE.” slip op. at 13

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable

    “Our construction of “pre-set UE number” is dispositive of this proceeding. See Section III.B.1 above. Petitioner agrees that both Li and Kim “don’t disclose that the message 3 includes a ‘pre-set number of UEs’” under our final construction of “pre-set UE number.” Pet. Reply 4; see also Tr. 7:20–22 (“Under [the District Court] construction, Li and Kim would not disclose Claim 1, at least Claim 1, of the ’430 patent”); 11:3–17 (Petitioner’s counsel arguing claim 18 is indefinite but agreeing neither claim 1 nor 18 have been shown unpatentable under the District Court construction of “preset UE number”). For the reasons set forth above, Petitioner has not shown a by a preponderance of the evidence that claims 1 and 18 are anticipated by Li.” slip op. at 18

  Patent outcomesUS 10,448,430 not shown unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,448,430
• Sony Group Corp. (Japan) / Sony Corp. Of America et al. v. MZ Audio Sciences, LLCNo claims unpatentable
  PTAB · Apr 8, 2024 · IPR2022-01544 · APJ Karl D Easthom · IPR · Final written decision

  Claims 1–10 were not shown unpatentable because Petitioner did not establish sufficient reasons to combine the references in any of the three obviousness grounds.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner asserts that a person of ordinary skill in the art “would have had a bachelor’s degree in electrical engineering or a related field with coursework in signal processing, plus two years of academic and/or industry experience in signal processing or a related field. More education could substitute for experience, and vice versa.” Pet. 7. “Patent Owner does not dispute Petitioners’ definition of a [person of ordinary skill in the art].” PO Resp. 2. Based on a review of the record, we adopt Petitioner’s proposed level of ordinary skill in the art because it is consistent with the evidence of record, including the asserted prior art, other references of record, and the ’961 patent specification.” slip op. at 7

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

    “district-court-type standard, as described in Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). See 37 C.F.R. § 42.100(b) (2020). Under this standard, claim terms have their ordinary and customary meaning, as would be understood by a person of ordinary skill in the art at the time of the invention, in light of the language of the claims, the specification, and the prosecution history. See Phillips, 415 F.3d at 1313–14. Petitioner relies on the plain and ordinary meaning and contends that it is unnecessary to construe any claim terms explicitly. See Pet. 8 (citing 37 C.F.R. §42.100(b)). Patent Owner “agrees with Petitioner that, for purposes of this Response only, all terms of the ᾽961 patent have their plain and ordinary meaning.” PO Resp. 23. As Petitioner contends, it is not necessary Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (stating 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 7

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

    “Dr. Scordilis. Based on the record, Petitioner fails to provide a sufficient reason to arrive at the claimed invention and satisfy the burden of showing obviousness. As Patent Owner essentially argues, Cabot (and all references relied upon by Petitioner and Dr. Scordilis) do not pertain to “quantizing a phase difference of the at least one overtone relative to the fundamental tone to embed at least one bit of the data to be embedded” as step 1C-2 requires. See PO Resp. 32–33. Petitioner also relies on Kudumakis to modify Srinivasan in asserting that step 1C-2 would have been obvious, but Petitioner’s reliance on Kudumakis is also faulty as explained below. See Pet. 22–27 (relying on Ex. 1006 (Cabot), Ex. 1007 (Kudumakis); Ex. 1028 (Risset), Ex. 1031 (Lipshitz), Ex. 1055 (“Cox-SSSW”); Ex. 1020 (“Cox- 1995” ); Ex. 1021 (“Wu”)). articulated reasoning with some rational underpinning” to show that one of ordinary skill in the art would have had a sufficient reason to modify Srinivasan’s frequencies to embed a quantized phase difference between a fundamental and its harmonic into the harmonic as step 1C-2 requires. See Kahn, 441 F.3d at 988 (“[R]ejections on obviousness grounds cannot be sustained by mere conclusory statements; instead, there must be some articulated reasoning with some rational underpinning to support the legal conclusion of obviousness”)); In re Fine, 837 F.2d 1071, 1075 (Fed. Cir. 1988) (“teachings of references can be combined only if there is some suggestion or incentive to do so”) (quoting ACS Hosp. Sys., Inc. v. Montefiore Hosp., 732 F.2d 1572, 1577 (Fed. Cir. 1984)). As noted above, Dr. Scordilis states that Cabot merely “opens the venue for exploration” for an artisan of ordinary skill to “try to . . . explore” watermarks. Ex. 2011, 75:16–22. Dr. Scordolis’s testimony relates to an “obvious to try” rationale, but neither Dr. Scordilis’s testimony, nor Petitioner’s showing, satisfies the conditions to support that rationale. In particular, Dr. Scordilis does not testify, and Petitioner does not show, that the technique of embedding phase difference codes into a harmonic relative to its fundamental was one of “a finite number of identified, predictable solutions” and a “known option[]” for hiding data. Cf. KSR, 550 U.S. at 402 (indicating that under an “obvious to try” rationale, “[w]hen there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person of ordinary skill in the art has good reason to pursue the known options within his or her technical grasp” (emphasis added)).” slip op. at 25

  • Expert testimonyPetitioner expert discountedDecided for patent owner

    “The record supports Patent Owner’s characterization of Dr Scordilis’s testimony. Dr. Scordilis does not rely on any references that “have a frequencies specifically.” See Ex. 2011, 90:4–8 (testifying such references are “[n]ot in [his] report”). Moreover, Dr. Scordilis testifies that “[t]he value . . . of Cabot’s work is that he points to the fact that even in this very controlled experiment, although phase is detectable in an A/B type of setup under many, many repetitions, it really opens the venue for exploration that a [person of ordinary skill in the art] would try to capitalize and explore further to develop a watermark.” Id. at 75:16–22 (emphasis added). In summary, Dr. Scordilis testifies that no references (including Cabot) cited in his declaration discuss phase encoding of a harmonic phase relative to a fundamental phase for watermarking, and Cabot merely opens the door so that a person of ordinary skill in the art would “try to . . . explore further to develop a watermark” using harmonic phase coding data. Id.” slip op. at 24

  Patent outcomesUS 7,289,961 not shown unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 7,289,961
• Samsung Electronics Co., Ltd. v. G+ Communications, LLCNo claims unpatentable
  PTAB · Mar 29, 2024 · IPR2022-01598 · APJ Gregg I Anderson · IPR · Final written decision

  The Board held claims 1, 2, 6, 8–11, 15, 17, and 18 not shown unpatentable over Kannan because Kannan did not disclose the construed transmission blocks.

  RulingsFinal written decision

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for patent owner

    “We are not persuaded that “single entity” requires a separate construction or additional clarification, presumably by “testimonial evidence.” See Pet. Supp. Br. 4 n.1. Here, we need not determine the precise outer bounds of the term “transmission block,” including all the different types of single entities, because the Board is required to construe the claim to only the extent necessary to resolve the dispute. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (citing Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)). The relevant context for understanding what is a single entity is the disclosures of Kannan and the ’443 patent regarding “code block,” “transport block,” and “transmission block.” Those are the “single entities” and are the focus of the dispute. For the preceding reasons we adopt our preliminary construction of “transmission blocks” as our final construction. No additional terms are in dispute that require construction.” slip op. at 16

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “invention of the ’443 patent “would have had an undergraduate degree in electrical engineering, computer engineering, computer science or a related field along with at least two years of work experience in the field of wireless communication technology.” Pet. 3–4 (citing Ex. 1003 ¶¶ 23–24). Patent Owner does not propose a level of ordinary skill and “takes no position with respect to Petitioner’s proposed level of ordinary skill in the art” because “it does not affect the ultimate analysis.” PO Resp. 11–12. For purposes of this Decision, we adopt Petitioner’s proposed level of ordinary skill because we are satisfied that it comports with the level of skill necessary to understand and implement the teachings of the ’443 patent. The proposed level of skill is consistent with the field of the invention as indicated by the cited prior art.” slip op. at 7

  • Expert testimonyPatent owner expert creditedPetitioner expert discountedDecided for patent owner

    “Kannan is based on the OSI model and describes control and data transmission on the MAC and PHY layers. Ex. 1006 ¶ 63. Kannan explains that “[w]ireless devices may exchange data using Medium Access Control (MAC) layer units known as transport blocks that may include a number of CBs.” Id. ¶ 8. Further, at the PHY layer, “a transport block may be divided into CBs.” Id. ¶ 52. Kannan continues to describe that “code blocks” “may be bundled into multiple bundles having a certain number of CBs.” Id. These parts of Kannan support the Akl Rebuttal Declaration conclusion’s regarding the OSI model in Kannan. Ex. 2007 ¶¶ 31–37, 49–50. Thus, we credit the Akl Rebuttal Declaration on this issue (id.) over Dr. Ding’s testimony (Ex. 1016 ¶ 13) because it is better supported by Kannan. Based on the preceding, we find that “code blocks” on the PHY layer are found only with “transport blocks” and are not a “separate entity.” See PO Supp. Br. 2.” slip op. at 21

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable

    “Kannan is based on the OSI model and describes control and data transmission on the MAC and PHY layers. Ex. 1006 ¶ 63. Kannan explains that “[w]ireless devices may exchange data using Medium Access Control (MAC) layer units known as transport blocks that may include a number of CBs.” Id. ¶ 8. Further, at the PHY layer, “a transport block may be divided into CBs.” Id. ¶ 52. Kannan continues to describe that “code blocks” “may be bundled into multiple bundles having a certain number of CBs.” Id. These parts of Kannan support the Akl Rebuttal Declaration conclusion’s regarding the OSI model in Kannan. Ex. 2007 ¶¶ 31–37, 49–50. Thus, we credit the Akl Rebuttal Declaration on this issue (id.) over Dr. Ding’s testimony (Ex. 1016 ¶ 13) because it is better supported by Kannan. Based on the preceding, we find that “code blocks” on the PHY layer are found only with “transport blocks” and are not a “separate entity.” See PO Supp. Br. 2. Thus, Petitioner has not shown that claims 1, 8, 10, and 17 are unpatentable by a preponderance of the evidence.” slip op. at 21

  Patent outcomesUS 10,594,443 not shown unpatentable
  Claim construction§ 102 anticipationcites Phillips
  Patents in suitUS 10,594,443
• Ebates Performance Marketing, Inc. D/B/A Rakuten Rewards v. International Business Machines Corp.No claims unpatentable
  PTAB · Oct 2, 2023 · IPR2022-00438 · APJ Ken B Barrett · IPR · Final written decision

  Claims 14–28 were not shown unpatentable because the petition did not establish that the asserted combination taught interactive execution of the ordering and annotation function.

  RulingsFinal written decision

  • Expert testimonyOther

    “annotation function . . . for comparing the user’s ‘user profile’ to the results obtained in the initial search.” Id. at 40–41 (citing Ex. 1005 ¶¶ 111–112, 116–117). Petitioner then concludes that, “[t]hus, Uchiyama discloses limitation [14d-2].” Id. at 41 (brackets in original) (citing Ex. 1003 ¶¶ 157– 160). Petitioner also asserts that: At a minimum, it was obvious to a [person of ordinary skill in the art] to have Uchiyama’s system compare a user’s profile to the returned search results “interactively at the time of each user query” so as to achieve Uchiyama’s goal of returning “more meaningful” search results as “the database grows” and “the search results for the same query improve over time.” (Ex-1005 at ¶0026; Ex-1003-Crovella at ¶162.) Hence, Uchiyama also renders obvious limitation [14d-2]. Id. at 41–42 (brackets in original). However, Petitioner does not elaborate on or explain the basis for this conclusory assertion of obviousness. Id.; see also Ex. 1003 ¶ 162 (Dr. Crovella stating the same). Although Petitioner’s analysis of limitation 14d-2 addresses the timing of the execution of the ordering and annotation function (the recited “at the time of each user query”), the analysis does not contain any form of the claim term “interactively,” other than when quoting the claim language. See Pet. 39–42. Thus, the Petitioner does not clearly and persuasively explain how “interactively” is disclosed or taught by Uchiyama.” slip op. at 17

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner contends that a person of ordinary skill in the art “would have at least a bachelor’s degree in computer science or a related field, plus at least one year of experience in the design and/or implementation of computerized information retrieval technology,” and that “[a]dditional education in the field of computer science may serve as a substitute for experience in the field.” Pet. 8 (citing Ex. 1003 ¶ 29). Patent Owner states that, “[f]or purposes of this proceeding, [Patent Owner] adopts Petitioner’s 4 The parties have not directed our attention to any objective evidence of obviousness or non-obviousness. proposed level of ordinary skill in the art.” PO Resp. 21 (citing Ex. 2011 ¶¶ 30–35). Petitioner’s definition is consistent with the level of ordinary skill reflected in the prior art references of record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (recognizing that the prior art itself may reflect an appropriate level of skill in the art). We apply Petitioner’s definition of the person of ordinary skill in the art.” slip op. at 7

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner

    “wherein the ordering and annotation function is executed interactively at the time of each user query” contains two requirements: 1) how the function is executed (“interactively”) and when the function is executed (“at the time of each user query”). Petitioner, in effect, reads out of the claim the “interactively” requirement. Petitioner offers no persuasive reason as to why that is correct. See In re Wilson, 424 F.2d 1382, 1385 (CCPA 1970) (“All words in a claim must be considered in judging the patentability of that claim against the prior art.”). Petitioner, for its proposed claim construction of a single requirement, primarily relies on the Specification’s statement that “the ordering and Annotation step 345 is executed interactively, e.g., at the time of every user query.” Ex. 1001, 8:10–12; see Pet. Reply 12–13 (citing the same for the proposition that “[t]he ’676 patent specification also ties the terms together”); Tr. 16:3–12 (“it’s clear the specification is saying that interactively means at the time of every user query”). Petitioner’s reliance on this statement is misplaced. First, Petitioner agrees that the plain and ordinary meaning of “interactively” means “some sort of interaction with the system,” that the inventor did not utilize its own lexicography to redefine the term “interactively,” and that the Specification does not evidence a disavowal of claim scope. See Tr. 19:4–20. Consistent with that, Petitioner acknowledges that the quoted part of the Specification merely is an example, and is not defining “interactively” as limited to that example. See id. at 19:19–25. Second, Petitioner misreads the Specification as indicating that “at the time of every user query” is an example of “interactively.” See, e.g., id. at 21:25–22:1 (“the way I read this is at the time of every user query is modifying what interactively means”). Rather, the better reading of the Specification’s phrase “executed interactively, e.g., at the time of every user query” is that “at the time of every user query” (as opposed to some other time) is an example of when the function may be interactively executed, not that the two phrases on either side of the “e.g.” are synonymous. slip op. at 21

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentableNot shown unpatentable

    “annotation function . . . for comparing the user’s ‘user profile’ to the results obtained in the initial search.” Id. at 40–41 (citing Ex. 1005 ¶¶ 111–112, 116–117). Petitioner then concludes that, “[t]hus, Uchiyama discloses limitation [14d-2].” Id. at 41 (brackets in original) (citing Ex. 1003 ¶¶ 157– 160). Petitioner also asserts that: At a minimum, it was obvious to a [person of ordinary skill in the art] to have Uchiyama’s system compare a user’s profile to the returned search results “interactively at the time of each user query” so as to achieve Uchiyama’s goal of returning “more meaningful” search results as “the database grows” and “the search results for the same query improve over time.” (Ex-1005 at ¶0026; Ex-1003-Crovella at ¶162.) Hence, Uchiyama also renders obvious limitation [14d-2]. Id. at 41–42 (brackets in original). However, Petitioner does not elaborate on or explain the basis for this conclusory assertion of obviousness. Id.; see also Ex. 1003 ¶ 162 (Dr. Crovella stating the same). Although Petitioner’s analysis of limitation 14d-2 addresses the timing of the execution of the ordering and annotation function (the recited “at the time of each user query”), the analysis does not contain any form of the claim term “interactively,” other than when quoting the claim language. See Pet. 39–42. Thus, the Petitioner does not clearly and persuasively explain how “interactively” is disclosed or taught by Uchiyama.” slip op. at 17

  Patent outcomesUS 6,785,676 not shown unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 6,785,676
• Amazon.Com, Inc. / Amazon Web Services, Inc. v. Swarm Technology LLCNo claims unpatentable
  PTAB · Aug 28, 2023 · IPR2022-00633 · APJ Michael R Zecher · IPR · Final written decision

  Claims 1–17 were not shown unpatentable because Lurie, alone or combined with the other cited references, did not teach proactive task retrieval; the contingent motion to amend was dismissed as moot.

  RulingsFinal written decision

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner

    “Based on the fully developed trial record, we apply the ordinary and customary meaning of the claim term “proactively” and, therefore, we construe this claim term as initiating change rather than reacting to events (i.e., not being told to act or not reactionary). Beginning with the intrinsic evidence, both parties appear to agree that the ’275 patent does not define the claim term “proactively” with reasonable clarity, deliberateness, and precision. For example, during the oral hearing, counsel for Amazon indicated that the specification of the ’275 patent provides “some examples” of what it means to act “proactively,” but it does not provide a lexicographic definition. See Tr. 7:8–11:21. In the same vein, during oral argument, counsel for Swarm stated that “[w]e haven’t advocated for anything other than the plain and ordinary meaning of proactively.” Id. at 34:23–24. We” slip op. at 12

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “In its Petition, Amazon argues that a person of ordinary skill in the art “would have had a bachelor’s degree in computer science, computer engineering, or a related field, and about five years of industry or academic research experience in parallel or distributed computing, system architecture, or an equivalent.” Pet. 4–5 (citing Ex. 1003 ¶¶ 42–44). Amazon further argues that “[a] post-graduate degree or additional formal education can compensate for less experience, and vice-versa.” Id. In its Patent Owner Response, Swarm does not address the level of skill in the art. See PO Resp. Accordingly, based on the fully developed trial record, we maintain our preliminary determination regarding the level of ordinary skill in the art. Dec. on Inst. 10–11. That is, we adopt Amazon’s proposed assessment of the level of ordinary skill in the art because it is consistent with the ’275 patent and the asserted prior art. We apply this assessment of the level of ordinary skill in the art in our obviousness evaluations below.” slip op. at 19

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “Amazon’s declarant, Dr. Lowenthal, provides testimony that supports our finding above. In his supplemental declaration in support of the Reply, Dr. Lowenthal testifies that, “[c]ertainly, Lurie initially sends an initial notification of ‘one or more tasks . . . becoming available.’ After that, . . . TCW [270] will obtain and process a first task.” Ex. 1040 ¶ 58 (quoting Ex. 1007 ¶ 86) (citing Ex. 1007 ¶¶ 87, 88) (second two alterations in original). He also testifies that the “one initial notification . . . kick[s] off the procedure” because it “informs all registered TCWs [270] that one or more tasks are available.” Id. ¶ 59. We credit the aforementioned testimony of Dr. Lowenthal’s because it is consistent with the disclosures in Lurie that we highlight above, most notably the kickoff notification.” slip op. at 30

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

    “As we explain in the claim construction section above, we accord the claim term “proactively” an ordinary and customary meaning of initiating change rather than reacting to events (i.e., not being told to act or not reactionary). See supra Section II.A. Contrary to our construction, Lurie’s TCW 270 only takes a task after receiving a kickoff notification and, therefore, it is not acting proactively. That is, Lurie’s TCW 270 reacts to the kickoff notification that a task is available or otherwise appears in object exchange repository 662 rather than initiates change by seeking a task from object exchange repository 662 without being notified to do so.” slip op. at 30

  Patent outcomesUS 10,592,275 not shown unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,592,275
• Juniper Networks, Inc. v. Swarm Technology LLCNo claims unpatentable
  PTAB · Apr 26, 2023 · IPR2022-00141 · APJ Michael R Zecher · IPR · Final written decision

  Juniper failed to show claims 1–7 and 9–17 unpatentable under any asserted obviousness ground because the combinations did not teach adding a co-processor without any communication with the controller.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “In its Petition, Juniper argues that a person of ordinary skill in the art “would’ve had at least a bachelor’s degree in computer science, electrical engineering, computer engineering, or a closely related field, and one or more years of experience in the design and development of parallel or distributed processing systems.” Pet. 11. Juniper further argues that a person of ordinary skill in the art could, alternatively, “have a master’s degree or similar post-graduate work in computer science, electrical engineering, computer engineering, or a closely related field, and less design and development experience.” Id. (citing Ex. 1003 ¶¶ 60, 61). In its Patent Owner Response, Swarm appears to agree with Juniper because it repeats verbatim the same assessment of the level of ordinary skill in the art offered by Juniper in its Petition. Compare PO Resp. 11, with Pet. 11. Accordingly, based on the fully developed trial record, we maintain our preliminary determination regarding the level of ordinary skill in the art. Dec. on Inst. 10. That is, we adopt Juniper’s proposed formulation of the level of ordinary skill in the art, except that we delete the qualifier “or more” to eliminate vagueness as to the amount of practical experience. The qualifier expands the range indefinitely without an upper bound and, therefore, precludes a meaningful indication of the level of ordinary skill in the art. We apply this modified version of the level of ordinary skill in the art in our obviousness evaluations below.” slip op. at 14

  • Expert testimonyPetitioner expert discountedDecided for patent owner

    “In any event, even if we were to consider Juniper’s downstream theory, we do not find this belated argument persuasive. To support its downstream theory, Juniper relies on the Dr. Weissman’s testimony that “[t]echniques for avoiding [broadcast packets flooding the network] are well known in the art and may include downstream devices dropping, or filtering, broadcast packets to minimize processing load.” Ex. 1031 ¶ 36. We decline to credit this testimony for two reasons. First, apart from generically asserting that dropping or filtering broadcast packets minimizes processing load, Dr. Weissman does not attempt to explain how Leong’s surveying unit would be considered a “downstream device” from a newly added co-processor, much less why Leong’s surveying unit would need to filter or drop a broadcast packet sent by the newly added co-processor. Second, Dr. Weissman does not cite to any underlying evidence to support his testimony. See 37 C.F.R. § 42.65(a) (“Expert testimony that does not disclose the underlying facts or data on which the opinion is based is entitled to little or no weight.”).” slip op. at 32

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

    “In any event, we need not construe any of the sixteen claim terms identified by Swarm in its Patent Owner Response because, when evaluating the merits of Juniper’s Petition in light of the arguments and evidence presented by Swarm during trial, the scope and meaning of the sixteen claim terms are not in controversy. Accordingly, it is not necessary to reach those particular issues for purposes of deciding whether Juniper has met its burden of demonstrating by a preponderance of the evidence that the challenged claims are unpatentable. See, e.g., Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))). In our obviousness evaluation below, we address the scope and meaning of the claim term “communication,” as this term pertains to the combined teachings of Leong and AppleTalkBook contested by the parties. More specifically, we address below whether Juniper’s proposed combination of Leong and AppleTalkBook teaches or suggests adding a coprocesser “on a plug-and-play basis without any communication with the controller,” as recited in each of independent claims 1, 6, and 11 of the ’275 patent.” slip op. at 11

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner

    “We begin our analysis with the plain language of independent claims 1, 6, and 11. Each of these independent claims explicitly requires adding a co-processor “without any communication with the controller.” Ex. 1001, 14:40–44, 15:30–34, 16:30–34 (emphasis added). As we explained in the Final Written Decision in IPR2021-01445, the use of the word “any” precludes both communication with a response and communication without a response. IPR2021-01445, Paper 62 at 25. Turning to the disclosure in the specification of the ’275 patent cited by Juniper, we do not agree that those disclosures support limiting “communication” to only two-way messaging. The relevant passage in the specification states the following: Each cell 12 [is] configured to perform one or a plurality of specialized tasks, as illustrated in the following sequence of events. During a poll phase each cell periodically sends an agent to the task pool until a matching task is found. To facilitate this matching, both the cell and the task pool may be equipped with a transceiver. In the case of the task pool, the transceiver maybe [sic] located in the task pool itself or in the switching fabric to which the task pool is connected. When a task match is found within a task pool, the task pool transmits an acknowledgement to the cell. The next step is the “communication channel” phase. During the communication channel phase, the cell receives the task and begins to execute the task. In one implementation, once the first task is completed, the communication channel is maintained so that the solidar[it]y cell can fetch another task without having to repeat the “poll” and “acknowledge” phase. Ex. 1001, 6:33–48 (emphases added). We fail to see how each cell 12 transmitting an acknowledgement message during the “poll phase” or each cell 12 receiving a task during the “communication channel” phase implicates adding a co-processor “on a plug-and-play basis,” as required by each of independent claims 1, 6, and 11. Regardless, we do not view the cited disclosure in the specification as limiting the “communication” required by these independent claims to only two-way messaging. Instead, we view the cited disclosure as merely examples of how each cell 12 may communicate with the task pool. The U.S. Court of Appeal for the Federal Circuit “has repeatedly ‘cautioned against limiting the claimed invention to preferred embodiments or specific examples in the specification.’” Williamson v. CitrixOnline, LLC, 792 F.3d 1339, 1346–47 (Fed. Cir. 2015) (quoting Teleflex, Inc. v. Ficosa N. Am. Corp., 299 F.3d 1313, 1328 (Fed. Cir. 2002)). Stated differently, these two examples of transmitting an acknowledgment message and receiving a task in the specification, by themselves, are not enough to prevent a broad interpretation of “communication” that includes, among other things, one-way messaging that does not require a response.” slip op. at 27

  Patent outcomesUS 10,592,275 not shown unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,592,275

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.