• Axon Enterprise, Inc. / Dedrone Holdings, Inc. et al. v. Airspace Defense, Inc.Some claims unpatentable
  PTAB · Oct 6, 2026 · IPR2025-00629 · APJ Scott C Moore · IPR · Final written decision

  Original claim 12 is not unpatentable; substitute claim 37 is added, while substitute claims 21–28 and 30–36 are denied as obvious.

  RulingsFinal written decision

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

    “F.3d at 1279–80, we begin our analysis with the Specification of the ’711 Patent. The Specification indicates when a UAV (such as the recited “reference aerial vehicle”) navigates autonomously, it flies without manual control, and can, for example, track and fly to a target using information captured onboard the vehicle itself. See Ex. 1001, 3:24–28 (“[I]t may not be desirable to manually control the interceptor aerial vehicle to follow the target UAV. In some embodiments, the interceptor aerial vehicle is able to autonomously track and fly to the target UAV using machine vision based on images captured by a camera of the interceptor aerial vehicle.”). The Specification also indicates that “autonomous” means more than just “automatic flight,” and clarifies that autonomous navigation occurs when a UAV that previously received a target location from an external source subsequently turns and flies itself towards the received location. See, e.g., id. at 4:15–17 (disclosing that the detected location of a target may be provided to an interceptor “to allow it to automatically and autonomously fly toward the direction of the detected location”); 15:64–16:3 (automatic and autonomous navigation occurs when an interceptor’s navigation component and/or flight controller receive the location of a target, and adjust the interceptor “to turn and fly towards the received location . . . based on the received location”); 16:49–60 (“For example, a flight direction and/or speed of an interceptor aerial vehicle are automatically and autonomously adjusted based on a location and size of the target within the captured image. . . . This allows the flight path of the interceptor aerial vehicle to be dynamically adjusted to track and follow a moving target.”).” slip op. at 11

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

    “have had reason to combine Beard and Laufer in the manner proposed by Petitioner, the combination would not satisfy the Autonomous Navigation limitation required by claim 12 because Laufer’s autopilot commands are generated by and transmitted from a remote command center (i.e., Laufer’s central controller 115). PO Resp. 15–16. In its Reply, Petitioner does not dispute that Laufer’s autopilot commands are generated by Laufer’s central controller 115, which is remote from the aircraft being controlled. See Reply 13–17. Petitioner asserts, however, that the combination still satisfies the Autonomous Navigation limitation because these autopilot commands are generated without human input. See id. Based on the complete trial record, Patent Owner’s arguments are persuasive. See PO Resp. 15–16; PO Sur-reply 42, 1–6; Ex. 2025 ¶¶ 84–87. The flight of Beard’s UAV 100 under the control of Laufer’s autopilot commands does not satisfy the Autonomous Navigation limitation of claim 12, as we have construed that limitation, because Laufer’s autopilot commands are generated at a location that is remote from UAV 100 (Laufer’s central controller 115.) See, e.g., Ex. 1010 ¶ 40 (“Central controller 115 uses autopilot command module 440 to generate autopilot aircraft commands”), ¶¶ 26, 30 (clarifying that central controller 115 and the controlled interceptor aircraft are separate devices that may communicate through a “wireless connection”), Fig. 4 (depicting “aircraft control commands 475” being generated externally from the depicted “Interceptor Aircraft”); see also Ex. 2025 ¶¶ 95–95. Petitioner never disputes that, in the proposed combination, Laufer’s central controller 115 would remain external to Beard’s UAV 100. See Reply 13–17. Instead, Petitioner relies on its proposed construction of the Autonomous Navigation limitation, which would have encompassed such an arrangement. See id. Our construction of the Autonomous Navigation limitation, which did not adopt Petitioner’s claim construction position, is dispositive of Petitioner’s argument. We thus determine that Petitioner has not shown by a preponderance of the evidence that claim 12 would have been obvious over Beard and Laufer.” slip op. at 15

  • PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend granted in partGranted in part

    “the legal requirements set forth in 35 U.S.C. § 316(d) and 37 C.F.R. § 42.121. Lectrosonics, Paper 15 at 4, 7–8. For the reasons that follow, we determine that Patent Owner has satisfied this burden. 1. Proposal of a Reasonable Number of Substitute Claims A motion to amend must “propose a reasonable number of substitute claims.” 35 U.S.C. § 316(d)(1)(B); see also 37 C.F.R. § 42.121(a)(3) (“A motion to amend may cancel a challenged claim or propose a reasonable number of substitute claims.”). “There is a rebuttable presumption that a reasonable number of substitute claims per challenged claim is one (1) substitute claim.” Lectrosonics, IPR2018-01129, Paper 15 at 4; see also 37 C.F.R. § 42.121(a)(3). Patent Owner has shown it proposes a reasonable number of substitute claims by proposing a single substitute claim for each of challenged claims 1–4, 8–11, and 13–20. MTA 1–2, Claims App. Petitioner does not argue otherwise. See generally MTA Opp. We determine that Patent Owner meets this requirement. 2. Amendments Respond to a Ground of Unpatentability “A motion to amend may be denied where … [t]he amendment does not respond to a ground of unpatentability involved in the trial.” 37 C.F.R. § 42.121(a)(2)(i). Patent Owner has responded to the grounds of unpatentability involved in this proceeding by amending the claims in response to the Petition’s asserted prior art. See MTA 2, 25, Claims App. Petitioner does not argue otherwise. See generally MTA Opp. We determine that Patent Owner meets this requirement. 3. No Enlargement of the Scope of the Claims An amendment may not seek to enlarge the scope of the claims of the patent. 35 U.S.C. § 316(d)(3); 37 C.F.R. §§ 42.121(b)(1)–(b)(2). Patent Owner asserts that the amendments in the Motion do not enlarge the scope of the claims of the patent because each proposed substitute claim “retains all of the limitations of the corresponding challenged claim, and each proposed independent substitute claim adds further limitations.” See MTA 2, Claims App. Petitioner does not argue otherwise. See generally MTA Opp. We determine that Patent Owner meets this requirement. 4. No Introduction of New Matter An amendment may not introduce new matter. 35 U.S.C. § 316(d)(3);” slip op. at 22

  • 112 supportDecided for patent owner

    “Having considered the evidence and argument cited by both parties, we determine there is sufficient written description support for the disputed portions of limitations [37.e1], [37.e3,] and [37.e4]. The ’452 application discloses selecting between groups of processing schemes (e.g., algorithms) depending on a confidence level, where the groups are, for example: high cost, high robustness algorithms; medium cost, medium robustness algorithms; and low cost, low robustness algorithms. See Ex. 2019 ¶¶ 146–147. These schemes or algorithms may be neural networks. See, e.g., id. ¶ 50 (including neural network as a type of algorithm); see also id. ¶¶ 109–110); see generally MTA Opp 1 (not disputing that schemes may be neural networks). Specifically, the ’452 application describes “algorithms that process video frames of one or more video data streams,” and “produce a prediction of objects within the video f[r]ame, as well as a confidence number that is a measure of quality for that prediction.” Id. ¶ 141. The ’452 application also discloses the concept of switching between neural networks based on confidence levels. In particular, the ’452 application discloses that a “process cycles through the processing schemes to produce a detection of an object,” for example, where “if the confidence number is higher than an activation number, an action is performed to stop or change a running group (i) and select or switch to group (ii).” Id. ¶ 146. More particularly, “a processing scheme from the group of (i) High cost (low refresh rate), high robustness algorithm[s] can select a cheaper processing scheme from the group of (ii) Medium cost, medium robustness algorithms.” Id. The ’452 application additionally discloses that schemes or algorithms (e.g., neural networks) are applied to individual video frames, and that the confidence levels that determine which neural network will be applied in the future are also derived from individual video frames. For example, as discussed above, the ’452 application describes that “[t]he processing schemes produce a prediction of objects within the video f[r]ame, as well as a confidence number that is a measure of quality for that prediction.” Ex. 2019 ¶ 141 (emphases added). The ’452 application also describes selecting and applying an individual neural network, rather than only selecting and applying a group of processing schemes. For example, as highlighted above, the ’452 application describes that “a processing scheme from the” “High” group “can select a cheaper processing scheme from the” “Medium” group. Id. ¶ 146 (emphases added). In our view, these disclosures, read together, would reasonably convey to one skilled in the art that the inventor had possession of the disputed subject matter described above. See Ariad, 598 F.3d at 1351.” slip op. at 24

  Patent outcomesUS 10,514,711 mixed
  Claim construction§ 103 obviousness§ 112 disclosurecites Phillips · Graham · Nautilus
  Patents in suitUS 10,514,711
• Medivis, Inc. v. Novarad Corp.Some claims unpatentable
  PTAB · Oct 1, 2026 · IPR2023-00042 · APJ Scott Raevsky · IPR · Remand

  Claims 1–6, 11, and 20 are unpatentable as obvious over Doo and Amira; claims 12–19 were not shown unpatentable because the asserted tissue properties were not shown in Amira.

  RulingsRemand decision

  • RemandOther

    “Federal Circuit. The court issued its decision in Medivis, Inc. v. Novarad Corp., No. 2024-1794, 2026 WL 587294 (Fed. Cir. Mar. 3, 2026) (“Medivis”) (Paper 40),1 affirming-in-part, reversing-in-part, and remanding our Final Written Decision (Paper 35) for further proceedings. In its opinion, the Federal Circuit reversed our “determination of no motivation to combine Doo and Amira” and remanded for further proceedings to evaluate whether claims 1–6 and 11–20 (“the Remanded Claims”) of U.S. Patent No. 11,004,271 B2 (“the ’271 patent,” Ex. 1001) are unpatentable in view of Petitioner’s obviousness challenge over Doo and Amira. Medivis, slip op. at 9–10. We have jurisdiction under 35 U.S.C. § 6(b). We issue this Final Written Decision on Remand pursuant to 35 U.S.C. §§ 144, 318 and 37 C.F.R. § 42.73 in an inter partes review involving Medivis, Inc. (“Petitioner”) and Novarad Corp. (“Patent Owner”). For the reasons discussed below, after considering the entirety of the record in light of the Federal Circuit’s directives in Medivis, we hold that Petitioner has demonstrated, by a preponderance of the evidence, that claims 1–6, 11, and 20 are unpatentable; however, Petitioner has not demonstrated, by a preponderance of the evidence, that claims 12–19 are unpatentable.” slip op. at 2

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “We adopt Petitioner’s proposed level of skill, except that we excise part of Petitioner’s definition to produce the following modified version: 4 Throughout this decision, we eliminate the parties’ italicization of reference names from quotations without noting “emphasis omitted.” 5 Doo, WO 2015/164402 A1, published October 29, 2015 (Ex. 1008). 6 Excerpt of Amira 5 User’s Guide, title through Chapter 2 (Visual Imaging 2009) (Ex. 1005). engineering, or a related field with several years of experience in the design, development, and study of augmented reality devices and . . . familiarity with conventional medical imaging data and visualization of data for medical procedures . . . . Our edit removes the alternative of “working with a team including someone with such familiarity” because one’s role in a team may be tangential to their personal experience with medical imaging. Regardless, had we adopted Petitioner’s original definition, our decision would not have changed.” slip op. at 6

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner

    “We agree with Petitioner that the term “3D slices” has no apparent connection to the phrase “direct volume rendering.” Patent Owner’s argument appears to be that DVR “requires an image of the entire anatomical volume that is neither feature-specific nor segmented, [which] would seemingly require that all inner layers be displayed.” Reply 4; see Sur-reply 6–10 (not disputing Petitioner’s characterization). But, as Petitioner notes, the specification directly undermines this by teaching “display [of] a slice of the 3D data instead of a volume of the 3D data.” See Reply 4 n.2 (quoting Ex. 1001, 5:34–35). In other words, to the extent DVR would depict an image of the entire anatomical volume, displaying 3D slices “instead of a volume of the 3D data” implies the opposite of DVR. Even if “3D slices” somehow implied DVR, Patent Owner’s position is still untenable. Claim 1 does not recite “3D slices.” Instead, claim 1 recites “3D data” and “inner layers.” Ex. 1001, 18:54–65. Patent Owner fails to clarify the relationship between “slices,” “3D data,” and “layers,” and its expert even admits that slices and layers are two different things. See PO Resp. 13; Ex. 1022, 32:7–16 (agreeing that the words “slice” and “layer” are not “synonyms”), cited in Reply 4. We also agree with Petitioner that dependent claim 3 distinguishes slices and layers by reciting “slices of the projected inner layer.” Reply 4 (quoting Ex. 1001, 19:3–10). Thus, even if 3D slices somehow implied DVR, the language of claim 1 does not support limiting the claim this way.” slip op. at 12

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

    “The determination of whether a document was publicly accessible “involves a case-by-case inquiry into the facts and circumstances surrounding the reference’s disclosure to members of the public.” Medtronic, Inc. v. Barry, 891 F.3d 1368, 1380 (Fed. Cir. 2018). For instance, courts routinely rely on the Wayback Machine to determine when a reference was first made available to the public. Valve Corp. v. Ironburg Inventions Ltd., 8 F.4th 1364, 1374 (Fed. Cir. 2021) (“District courts have taken judicial notice of the contents of webpages available through the Wayback Machine ‘as facts that can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.’”). We disagree with Patent Owner’s argument that “Medivis cannot rely on additional prior art”—Exhibits 1023 and 1024—“that was submitted after its Petition to carry its burden without leave from the Board.” Sur-reply 4. As Patent Owner did not file a motion to exclude these exhibits, we decline Patent Owner’s invitation to disregard them. We also find Petitioner’s Reply argument proper because it directly responds to Patent Owner’s contention that Petitioner did not prove the public accessibility of Amira. See Chamberlain Grp., Inc. v. One World Techs., Inc., 944 F.3d, 919, 925 on issues previously raised.”). Petitioner’s Reply argument appropriately elaborates on the Petition’s contention that Amira was publicly accessible. Patent Owner also does not dispute the substance of Petitioner’s evidence. For example, Patent Owner does not address the substance of Mr. Frank-White’s declaration. We find that this evidence, including Mr. Frank- White’s declaration testimony, persuasively supports the public availability of Amira as of the date shown in the Wayback Machine URL. See Ex. 1024.” slip op. at 22

  Patent outcomesUS 11,004,271 mixed
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips
  Patents in suitUS 11,004,271
• Google LLC v. Withrow Networks Inc.All claims unpatentable
  PTAB · Sep 25, 2026 · IPR2025-00775 · APJ Justin T Arbes · IPR · Final written decision

  Claims 1–9 are unpatentable as obvious over each of the five asserted §103 grounds, including Carmel with Mattavelli and Carmel with Wang.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner argues that at the relevant time of the invention claimed in the ’849 patent (April 2005),2 a person of ordinary skill in the art would have had “at least a bachelor’s degree in computer science, computer engineering, electrical engineering, or an equivalent field requiring learning computation principles, and two years of work experience in networking or streaming media systems, particularly audio and video, over the Internet,” where “[a]dditional education could compensate for less practical experience and vice versa.” Pet. 5–6 (citing Ex. 1002 ¶¶ 18–23). In the Decision on Institution, the Board agreed with and applied Petitioner’s proposed definition. Dec. on Inst. 9–11. Patent Owner proposes a very similar definition of “a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and two to three years of experience in the design or development of (1) video processing systems, audio processing systems, and/or the equivalent; and (2) networking and communications systems, or the equivalent,” where “[a]dditional graduate education could substitute for professional experience, or significant experience in the field could substitute for formal education.” PO Resp. 23 2 Petitioner states that it “uses [the earliest possible priority date of April 18, 2005] as the priority date of the challenged claims.” Pet. 6. Patent Owner agrees that the “earliest effective filing date” of the challenged claims is April 18, 2005. PO Resp. 19. The ’849 patent is expired. See Ex. 1001, codes (63), (*); Paper 8, 33. would be the same under either level” of ordinary skill in the art. Id. Based on the full record developed during trial, including our review of the ’849 patent and the types of problems and solutions described in the ’849 patent and cited prior art, we maintain the previously adopted definition of the level of ordinary skill in the art, but remove the term “at least” to avoid unnecessary ambiguity. Our analysis herein, however, would be the same under either party’s proposed definition.” slip op. at 7

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

    “37 C.F.R. § 42.100(b). Petitioner states in the Petition that it “does not presently contend that any term requires express construction.” Pet. 6. Patent Owner “does not believe any terms of the ’849 [p]atent require express constructions for purposes of” this proceeding. PO Resp. 24; Sur-Reply 11. The Board did not interpret any terms in the Decision on Institution. Dec. on Inst. 8. We agree that no terms require express interpretation to determine whether Petitioner has met its burden to prove unpatentability of the challenged claims. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“Because we need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy,’ we need not construe” slip op. at 8

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

    “Finally, Petitioner explains in detail why and how a person of ordinary skill in the art would have had reason to combine the teachings of Carmel and Mattavelli, with a reasonable expectation of success. See Pet. 50–55. Specifically, an ordinarily skilled artisan would have modified Carmel’s system to use “Mattavelli’s CGD techniques to optimize the decoding of in more efficient network bandwidth usage and improved playback of multimedia data streams. Id. at 50, 52–53, 55. Petitioner contends that Carmel and Mattavelli are both directed to processing multimedia data playback “for the appreciation of a user,” while providing the highest perceived audio and video output quality possible in view of system constraints to ensure playback continuity. Id. at 50–51 (citing Ex. 1003, 7:35–49, 10:48–54, 11:9–18, Figs. 3D, 6B; Ex. 1004, 2309–10). Petitioner argues that Carmel and Mattavelli both pertain to compression of multimedia data using well-known coding and compression standards for video streaming. Id. at 51 (citing Ex. 1003, 7:25–26, 11:24–52; Ex. 1004, 2309–11). Petitioner further asserts that a person of ordinary skill in the art would have appreciated that Carmel and Mattavelli “complement[]” each other because Carmel addresses constraints on available network bandwidth and Mattavelli addresses limits on available processing resources at the client/multimedia player. Pet. 52 (citing Ex. 1003, code (57), 7:36–41; Ex. 1004, 2309–2312). According to Petitioner, an ordinarily skilled artisan would have been motivated to combine the complementary teachings in Carmel and Mattavelli to create a more robust streaming system that addresses both bandwidth constraints and client processing limits to provide the best possible playback experience. Id. (citing Ex. 1002 ¶¶ 212–215). Petitioner also contends that Mattavelli teaches that merely optimizing transmission bandwidth is not sufficient and is potentially harmful, which provides an express motivation to combine Carmel’s and Mattavelli’s complementary teachings to ensure that different, related links in the streaming playback chain are optimized together. Id. at 53 (citing Ex. 1002 express disclosure that would have motivated a person of ordinary skill in the art to incorporate Mattavelli’s complementary teachings regarding decoding because Carmel states that multimedia playback is achieved “preferably with only a minimal necessary transmission and decoding delay.” Id. at 53–54 (quoting Ex. 1003, 10:50–54; citing Ex. 1002 ¶ 218). Patent Owner in its Response does not dispute that Carmel and Mattavelli teach the preamble and limitations 1[a.i]–1[c.i], or that a person of ordinary skill in the art would have been motivated to combine the references’ teachings in the manner asserted by Petitioner.6 Nonetheless, the burden remains on Petitioner to demonstrate unpatentability. Dynamic Drinkware, 800 F.3d at 1378 (discussing the burden of proof in inter partes review). Having reviewed Carmel and Mattavelli, on the complete trial record, we agree with Petitioner’s analysis, as supported by the testimony of” slip op. at 22

  Patent outcomesUS 10,771,849 unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,771,849
• Amazon.Com, Inc. / Amazon.Com Services LLC et al. v. Soundclear Technologies LLCAll claims unpatentable
  PTAB · 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 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 11,069,337
• Mediatek Inc. v. Parkervision, Inc.All claims unpatentable
  PTAB · May 22, 2026 · IPR2024-00796 · APJ Iftikhar Ahmed · IPR · Final written decision

  Claims 1–20 are unpatentable as obvious over Nevo and Avitabile, Young and Estabrook, and Young, Estabrook-1988, and Estabrook-1989.

  RulingsFinal written decision

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

    “Network LLC, 929 F.3d 1350, 1357 (Fed. Cir. 2019). On its face, the language “energy transfer signal” does not specify any restrictions on the type of system in which it is utilized, nor its characteristics. In the context of claims 1 and 11, the “energy transfer signal” is the basis on which the “switch” operates, so as to “sub-sample and transfer energy from a first electromagnetic (EM) signal.” Ex. 1001, 50:63–65, 51:56–58. Accordingly, based on the claim language, the term “energy transfer signal” need only be a signal for operating a switch to sub-sample and transfer energy from an electromagnetic signal. That is its plain and ordinary meaning.” slip op. at 15

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

    “’686 patent broadly includes knowledge and experience as to RF circuit design. See supra § III.B. Petitioner contends that “Nevo’s transceivers [102a/102b] are for Bluetooth and IEEE 802.11,” and that a person of ordinary skill in the art would have understood that both protocols “required down-conversion in their receivers to obtain a baseband signal.” Id. at 35 (citing Ex. 1004, 4:45–50; Ex. 1002 ¶ 118). Nevo’s disclosure would have motivated a person of ordinary skill in the art to look to Avitabile, which provides the circuit level detail for down-converters. See Ex. 1006, Abstract. Avitabile specifically provides circuitry for down-conversion in the s-band frequency range, which is in the range of Bluetooth and IEEE 802.11 (2.4 GHz). Id. at Abstract, Figs. 6, 7. Accordingly, we determine a person of ordinary skill in the art would have been motivated to look to down-converters in the range of frequency needed, and would have been motivated to combine Avitabile’s teachings with those of Nevo, with a reasonable expectation of success.” slip op. at 55

  • Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner

  Patent outcomesUS 7,483,686 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 7,483,686
• Mediatek Inc. v. Parkervision, Inc.All claims unpatentable
  PTAB · Mar 31, 2026 · IPR2025-00030 · APJ Barry L Grossman · IPR · Final written decision

  Claims 1–20 are unpatentable as obvious over the combinations in Grounds 1A–1C and 2A–2C.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “stated by Patent Owner. Ex. 2001 ¶ 25. This proposed level of skill is nearly identical to that proposed by Petitioner. Unlike Dr. Larson, however, Dr. Ricketts states his “opinion,” without stating the facts, data, or factors that he considered in reaching his opinion. Accordingly, we give his testimony little probative weight. 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.”). For purposes of this Decision, based on the prior art, the sophistication of the disclosed technology in the ’593 patent, and Dr. Larson’s testimony, we adopt Petitioner’s definition of the level of ordinary skill, which is that a person of ordinary skill in the art would have had: at least a bachelor’s degree in electrical engineering or a related subject and two or more years of experience in the field of RF circuit design and/or power supplies for RF circuits, or at least five years of work experience and training in the design and development of RF circuits and/or power supplies for RF circuits. Less work experience may be compensated by a higher level of education, such as a master’s degree.” slip op. at 15

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed petitioner constructionDecided for petitioner

    “on the construction of the claim term “power efficiency,” we agree with Petitioner and its declarant, Dr. Larson, that a person of ordinary skill (i.e., a degreed engineer with two or more years of experience in the field of RF circuit design and/or power supplies for RF circuits) would have understood that to determine the power efficiency of a circuit, one would measure the components or characteristics of power, such as voltage and current, to determine the output power of the power supply compared to its input power. Based on our construction of the claim term “power efficiency,” we also note that the claims only require performing a bypass function when the efficiency threshold is exceeded. The claims do not require a power efficiency ratio to be measured or calculated. Thus, we decline Patent Owner’s attempt to limit the claim term “power efficiency” to a ratio.” slip op. at 30

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

    “Section II.D.2 of this decision), Hau teaches a bypass controller 74 (purple) which receives a signal Pdet from a power detector (pink) and activates a bypass switch 72 (purple) when the signal Pdet exceeds a predetermined threshold (in response to a power efficiency of the power supply exceeding a predetermined threshold). Id. at 28 (citing Ex. 1007, 5:43–51, 6:57–7:20). According to Petitioner Hau discloses that the strength of the signal Pdet, the power output of the amplifier PA1, and the supply voltage Vcc2 are all proportional. Id. at 29 (citing Ex. 1007, 6:22–44; Ex. 1003 ¶¶ 122–123. Petitioner concludes, therefore, that Pdet is an indicator of the power output by the DC-DC buck regulator at Vcc2. Id. Petitioner also concludes that because input power is supplied to the DC-DC buck regulator from a fixed voltage, Pdet is also an indicator of the power efficiency of the DC-DC buck regulator because higher power indicated at Pdet indicates greater efficiency relative to the fixed input power. Pet.29 (citing Ex. 1003 ¶ 123). Dr. Larson’s testimony supports Petitioner’s conclusions. Petitioner also asserts: when Pdet exceeds the predetermined threshold, Hau’s bypass controller 74 activates bypass switch 72 and deactivates the DC- DC converter (which is a PWM switching device in the combination of Hau and Yoshida) (deactivates the switching device) to pass the input voltage directly to the output voltage Vcc2 (passes the input voltage to the output voltage node). Pet. 30 (citing Ex. 1007, 5:44-51, 6:61, 66; Ex. 1003 ¶¶ 125-126).” slip op. at 39

  • Obviousness (§103) › Motivation to combine / reasonable expectation of success › HindsightUnpatentableMotivation foundUnpatentable

    “According to Petitioner, it would have been obvious to a person of ordinary skill “to set Hau’s predetermined threshold to correspond to the point at which a fixed power supply (e.g., the bypass pathway of Hau) becomes more efficient than the down-converted power supply, as taught by Sahu.” Pet. 50–51 (citing Ex. 1007, 6:63–66; Ex. 1003 ¶¶ 166–167). Petitioner also asserts a person of ordinary skill “would have recognized that Sahu’s efficiency graph shows performance for a particular modulation scheme”, and that the resulting efficiency of the system using that modulation scheme “correlates with the efficiency of the communication waveform in that scheme (based on a communication waveform efficiency).” Id. at 51 (citing Ex. 1003 ¶ 168). Petitioner concludes that a person of ordinary skill “would have understood and found it obvious that basing the predetermined threshold of Hau on the point where a fixed power supply becomes more efficient as taught by Sahu is programming the threshold voltage based on a communication waveform efficiency.” Id. at 51 (citing Ex. 1003 ¶ 168). We find Petitioner’s contentions persuasive. Patent Owner asserts it is “hindsight” to rely on Sahu. PO Resp. 51 (a person of ordinary skill “would not have equated Sahu’s fixed-supply system with Hau’s bypass pathway without the benefit of hindsight”). According to Patent Owner, “Petitioner used the disclosures in the ’593 patent as a road map for reasons to combine Sahu and Hau/Yoshida.” Id. (citing Ex. 2001, ¶¶ 174–75). Patent Owner also asserts a person of ordinary skill “would have recognized that Figure 8(a) of Sahu “relates to specific devices that were tested in Sahu.” Id. at 50. We find these assertions unpersuasive. We have discussed above the” slip op. at 57

  Patent outcomesUS 8,498,593 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,498,593
• Cisco Systems, Inc. v. Portsmouth Network Corp.No claims unpatentable
  PTAB · Mar 31, 2026 · IPR2024-01450 · APJ Peter D Shapiro · IPR · Final written decision

  Claims 1–4, 6–11, and 13–20 were not shown unpatentable because Dziong and Sathyanath do not teach the claimed sharing definition for existing connections with allocated bandwidth.

  RulingsFinal written decision

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

    “First, the claims use present-tense language, “one or more other connections, which have respective bandwidths and which are permitted to share a bandwidth allocation with the new connection.”3 Ex. 1001, claim 1 (emphasis added). The exclusive use of the present tense have indicates “other connections” must have current possession of the bandwidth. For these other connections to share bandwidth with a newly established connection, they must already exist and have bandwidth ready for immediate use, rather than merely holding a dormant “reservation” pending a network failure. See PO Supp. Br. 1. The Federal Circuit addressed a similar situation where the Court found the present-tense limitation “is connected to the computer network” means a device was required to be connected at the” slip op. at 15

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

    “combination, do not teach or suggest limitations 1.2 and 1.3 requiring: providing a sharing definition specifying one or more other connections, which have respective bandwidths and which are permitted to share a bandwidth allocation with the new connection, such that a total bandwidth allocated jointly to the new connection and to the other connections in any given segment is equal to a maximum of the requested bandwidth and of the bandwidths of the other connections in the given segment Ex. 1001, limitations 1.2, 1.3 (emphasis added); see PO Resp. 17–22; Sur-reply 4–5, 12–14. As discussed above in Section II.C.2, we interpret “other connections” to mean “existing connections in the network that already have bandwidth allocated to them.” Because the information shared in Dziong and Sathyanath, described below, relates to reserved protection paths, rather than existing connections that have bandwidth that can currently transmit network traffic, the references do not teach or suggest the “other connections” part of the sharing definition in limitations 1.2 and 1.3. Dziong describes advertising, across the network, the amount of bandwidth reserved for recovery on each link that would be activated when a protected link fails. See, e.g., Ex. 1005 ¶ 60; Pet. 36. Once activated, network traffic from a “primary path” failure is rerouted to these recovery paths. See Ex. 1005 ¶¶ 7–9, 70, 83. Petitioner points to this advertising of the reserved bandwidth information as teaching the claimed “sharing definition.” Pet. 33–36 (arguing that the “protection paths [in Dziong] have bandwidth reservations” and “share an overall protection bandwidth reservation”); Reply 21–23. However, since the advertised information only contains information about the recovery paths “that would be activated” upon a primary path failure, such paths are not existing connections that already have bandwidth allocated to them, and therefore do not teach the claimed “other connections” that are part of the sharing definition. See, e.g., Ex. 1005 ¶ 60.” slip op. at 43

  Patent outcomesUS 7,596,088 not shown unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 7,596,088
• Valve Corporation v. Immersion CorporationAll claims unpatentable
  PTAB · Mar 23, 2026 · IPR2024-00582 · APJ Christopher L Ogden · IPR · Final written decision

  Claims 1–6, 14–16, and 19 are unpatentable based on anticipation by or obviousness over Pratt, and obviousness over Pratt–Ku, Ku, or Ku–Jiang.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “The parties agree that formal education could substitute for practical experience, and vice versa. Pet. 6, PO Resp. 18. The parties’ proposed levels of ordinary skill appear to be substantially similar, supported by testimonial evidence, and consistent with the asserted prior art and the types of problems and solutions identified in the ’738 patent. See, e.g., Ex. 1001, 1:6–61. Although we discern no difference in the outcome of this decision from choosing one over the other, we adopt Petitioner’s proposed level of skill for this decision. The outcome of our decision would be the same under Patent Owner’s proposal.” slip op. at 7

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner

    “We find insufficient support in the specification or prosecution history to narrow the term “haptic effect” to only one that has not been modified or combined with another haptic effect. The ’738 patent still refers to combined or modified haptic effects as a “haptic effect.” Ex. 1001, 11:35–38 (“a haptic effect may further be modified or combined with another haptic effect” and “the haptic effect can include one or more haptic effects”). We also find no support for importing into the construction of “haptic effect” the ’738 patent’s example in which a haptic effect can be “based on the proximity signal and the touch sensor signal.” That is already an explicit claim limitation. Id. at 14:19–20 (“generate a haptic output signal based at least in part on the first [proximity] and second [touch] sensor signals”). Including that limitation as part of the construction of “haptic effect” would render the limitation superfluous. See Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1237 (Fed. Cir. 2016) (“The Board was correct to not include in its construction of ‘menu’ features of menus that are expressly recited in the claims . . . . Construing a claim term to include features of that term already recited in the claims would make those expressly recited features redundant.”). We also disagree with Patent Owner that the ’738 patent’s references to haptic effects modified or combined with other haptic effects are unclaimed embodiments. The ’738 patent discloses that a proximity-based haptic effect may be combined with a touch-based haptic effect, such as when “a particular haptic effect associated with a particular control on a user interface element [is] further . . . modified or combined with another haptic effect based on the proximity sensor signal,” or when “the haptic effect [to be output by the processor] . . . include[s] a haptic effect meant to confirm ‘pushing’ on a virtual button.” Ex. 1001, 11:32–40. These examples are consistent with the claim language and we find no credible evidence in the record that these embodiments are intended to be excluded from the claimed invention. Thus, we agree with Petitioner that it would be incorrect to construe the term “haptic effect” to include the extraneous limitations Patent Owner proposes. We also agree with Petitioner that a person of ordinary skill in the art reading the ’738 patent disclosure would have understood that a combined or modified haptic effect is still a haptic effect.” slip op. at 11

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable

    “To show anticipation under § 102, a petitioner must locate every element in a claim, arranged as recited in the claim, in a single prior art reference. See Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359, 1369 (Fed. Cir. 2008). The limitations may be present in the reference “either explicitly or inherently.” In re Schreiber, 128 F.3d 1473, 1477 (Fed. Cir. 1997). In making this determination, we consider the reference “together with the knowledge of one of ordinary skill in the pertinent art.” In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994) (citing In re Samour, 571 F.2d 559, 562 (CCPA 1978)).” slip op. at 13

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

    “We find Petitioner’s arguments persuasive and disagree with Patent Owner’s arguments to the contrary. Ku discloses summing two overlapping vibration signals, one “based at least in part on” data from a proximity sensor and another “based at least in part on” data from a touch sensor. Ex. 1008, Fig. 12 (items 705, 710, and 715). The summed signal 715 is the basis for generating what the user would perceive as a single haptic effect. See Ex. 1004 ¶ 210–212. This meets limitation 1F. We agree with Petitioner’s argument as to why there would have been a motivation to modify Pratt to include Ku’s teachings. Petitioner’s argument is not merely that Pratt was ready for improvement; Petitioner persuasively argues that a person of ordinary skill in the art would have had reason to add Ku’s method for confirming that the user has touched the intended icon to Pratt’s system. Both Pratt and Ku already disclose using both proximity and touch data in generating a haptic effect, and based on the evidence of record, we are of the view that combining the two teachings would not have been uniquely challenging or otherwise beyond the level of ordinary skill in the art. See Leapfrog Enters., Inc. v. Fisher-Price, Inc., 485 F.3d 1157, 1162 (Fed. Cir. 2007) (“Leapfrog presents no evidence that the inclusion of a reader in [electronic children's toys] was uniquely challenging or difficult to one of ordinary skill in the art.” (citing KSR, 550 U.S. at 419–420))” slip op. at 32

  Patent outcomesUS 11,175,738 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,175,738
• Magic Leap, Inc. v. Percept Technologies Inc.All claims unpatentable
  PTAB · Mar 11, 2026 · IPR2023-00495 · APJ Kristen L Droesch · IPR · Remand

  Claims 1–3 and 12–14 are unpatentable as obvious over Osterhout and, separately, over Mann ’526 and Vaissie.

  RulingsRemand decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “March 15, 2013 filing date, a person of ordinary skill in the art (“POSITA”) would have had a B.S. degree and a Masters degree in Computer Science, Computer Engineering, Electrical Engineering, Physics, or an equivalent field, as well as one to two years of academic or industry experience in wearable electronic devices or comparable industry experience. Pet. 8–9 (citing Ex. 1003 ¶ 21). Although the level of skill in the art was addressed in the Preliminary Response and the Decision on Institution (see Prelim. Resp. 27–30; Dec. on Inst. 6–10), Patent Owner does not address Petitioner’s definition of the level of ordinary skill in the art. See PO Resp. We adopt Petitioner’s definition of a person of ordinary skill in the art because it is consistent with the level of skill reflected by the ’113 Patent Specification and the asserted prior art.” slip op. at 7

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

    “For all of the foregoing reasons, we decline to adopt Patent Owner’s proposed ordinary and customary meaning for “a dynamic eye tracking mechanism in communication with the lens” because it is not supported by the claim language or the ’113 Patent Specification, and is supported only by unsworn attorney argument.” slip op. at 13

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

    “below, we agree with Petitioner. We find that Osterhout teaches the dynamic eye tracking mechanism is in optical communication with the lens, consistent with its ordinary and customary meaning, because in Osterhout the user’s eye receives optical communication in the form of light transmitted from the translucent lens, and the camera of the dynamic tracking mechanism, in turn, receives optical communication in the form of light from the user’s eye. See Ex. 1005 ¶¶ 164, 304.” slip op. at 20

  Patent outcomesUS 8,696,113 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,696,113
• Juniper Networks, Inc. v. Portsmouth Network Corp.All claims unpatentable
  PTAB · Dec 9, 2025 · IPR2024-00893 · APJ Justin T Arbes · IPR · Final written decision

  Claims 3, 8, 11, 12, 15, 20, 23, and 24 are unpatentable as obvious over Gai and IEEE 1999.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner argues that at the time of the application for the ’986 patent (January 2002), a person of ordinary skill in the art would have had “a bachelor’s degree in electrical engineering or a related field, plus at least two years of industry experience or graduate-level academic experience with computer networking.” Pet. 20. In the Decision on Institution, the Board agreed with and applied Petitioner’s proposed definition, removing the phrase “at least” to avoid unnecessary ambiguity. Dec. on Inst. 18–19. Patent Owner uses Petitioner’s proposed definition for its Response. PO Resp. 5. Neither party made any further argument regarding the level of ordinary skill in the art in its papers during trial. In the Cisco IPR, we adopted a similar definition, determining that a person of ordinary skill in the art would have had “a bachelor’s degree in computer science, computer engineering, electrical engineering, or in an equivalent field, or approximately two years of experience working in the field of information technology and networking,” where “[l]ack of professional experience can be substituted by additional education, and vice versa.” IPR2024-00505, Paper 29 at 10–11 (alteration in original); see Dec. on Inst. 19 n.7 (noting the proposed definition in the Cisco IPR). Based on the full record developed during trial, including our review of the ’986 patent and the types of problems and solutions described in the ’986 patent and cited prior art, we adopt the same definition of the level of ordinary skill in the art as the Cisco IPR and apply it for purposes of this Petitioner’s similar proposed definition in this proceeding.” slip op. at 12

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “Gai discloses entering an Enable_Uplinkfast command at an access switch (e.g., access switch 114) to block a failed port (e.g., the root port) and configure the access switch to send dummy traffic upstream through a new active port. . . . When modified in view of IEEE 1999’s disclosure that self-healing network traffic can advantageously be sent both upstream and downstream, the command would be entered at a backbone switch (e.g., backbone switch 122) to block a failed port (e.g., a designated port connected to access switch 114) and configure the backbone switch to send dummy traffic downstream to an access switch (e.g. access switch 114) through a new active port. While Gai uses its protocol signaling command, Enable_Uplinkfast, to send dummy traffic through a new root port, [a person of ordinary skill in the art] would deem it an obvious implementation detail to modify the parameters of the port on a backbone switch. See Ex. 1003 ¶ 139 (citing Ex. 1005, col. 6, ll. 39–46).” slip op. at 34

  • Prior constructionPrior construction adoptedDecided for petitioner

    “In the Cisco IPR, we addressed four claim terms in the final written decision: “access switch” and “edge switch,” which appear in independent claims 1 and 13 and various dependent claims, and “downstream” and “upstream,” which appear in claims 11, 12, 23, and 24. IPR2024-00505, Paper 29 at 11–14. We interpreted “access switch” to mean “a switch with ports that connect to LANs and/or to other network endpoints, such as user computer systems,” interpreted “edge switch” to mean “a core switch that is directly connected to an access switch,” interpreted “downstream” to mean “away from the root switch,” and interpreted “upstream” to mean “toward the root switch.” Id. As noted above, Patent Owner did not appeal that decision. We incorporate herein our previous analysis in the Cisco IPR, but note that none of the analysis of the disputed issues below depends on such determine whether Petitioner has met its burden to prove unpatentability of the challenged claims. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“Because we need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy,’ we need not construe [a particular claim limitation] where the construction is not ‘material to the . . . dispute.’” (emphasis added) (citation omitted)).” slip op. at 13

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

    “1999, supported by the testimony of Mr. McNair, which we credit, is persuasive. See Pet. 25–30, 40–46; Ex. 1003 ¶¶ 132–145, 165–174. Based on the full trial record, we find that Gai and IEEE 1999 teach limitation [1E] and that a person of ordinary skill in the art would have been motivated to combine their teachings in the manner described by Petitioner. Based on all of the evidence of record, we determine that Petitioner has proven, by a preponderance of the evidence, that claim 3 would have been obvious over Gai and IEEE 1999 under 35 U.S.C. § 103(a). 4. Claims 8, 15, and 20 Claim 8 depends indirectly from independent claim 1. Claims 15 and 20 depend indirectly from independent claim 13, which is similar to claim 1 but recites a network switching device rather than a method. As to independent claim 13, Patent Owner refers to its earlier arguments regarding claim 1, asserting that limitation [13C] is “substantially similar” to limitation [1E]. PO Resp. 14–15. We disagree with Patent Owner’s arguments for the reasons explained above. See supra Section II.D.3.b. Patent Owner does not argue dependent claims 8, 15, and 20 separately from their respective parent claims 1 and 13. See PO Resp. 19. We have reviewed Petitioner’s contentions and supporting evidence, including the testimony of Mr. McNair, and are persuaded that Petitioner has proven, by a preponderance of the evidence, that claims 8, 15, and 20 would have been obvious based on Gai and IEEE 1999 under 35 U.S.C. § 103(a), for the reasons stated by Petitioner. See Pet. 21–46, 48–52, 55–59; Ex. 1003 ¶¶ 113–175, 179–185, 194–203.” slip op. at 41

  Patent outcomesUS 6,917,986 unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 6,917,986

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.