- Microsoft Corporation v. Sterling Computers CorporationAll claims unpatentablePTAB · Sep 14, 2026 · IPR2025-00270 · APJ Bach V Hoang · IPR · Final written decision
Claims 1–13, 15, 18, 20, 21, and 27 are unpatentable as obvious over Rohall and Schiavone, with Gomes added for claims 9 and 27.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Our Institution Decision adopted Petitioner’s definition of a person of ordinary skill in the art. Inst. Dec. 9–10. In its Response, Patent Owner adopts Petitioner’s proposed level of ordinary skill. See PO Resp. 16 (“Patent Owner and its expert adopt the Board’s definition for purposes of this Response.”). Having considered the record, we continue to adopt Petitioner’s proposed level of skill, as articulated above. We are satisfied that Petitioner’s proposal comports with the level of skill necessary to understand and implement the teachings of the ’911 Patent. Accord Inst. Dec. 9–10.” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“We agree with Petitioner and determine that the construction of “relational references” does not require the use of a relational model and, further, includes pointers that point to related messages exchanged among users. The intrinsic evidence leads us to this construction. First, the relevant language of claim 1 recites “a message container containing relational references pointing to a plurality of sent submessages stored externally to the message container in the message database.” Ex. 1001, 15:56–59. A relational model is not recited in that language or anywhere else in the claim. See id. at 15:51–16:14. Therefore, the claim does not expressly require a relational model. Furthermore, the claim language supports Petitioner’s interpretation that “relational references” include pointers that point to related messages because the claim states that the “relational references” perform the task of “pointing to a plurality of sent submessages.” Pet. Reply 7. Accordingly, the language of the claim supports a construction that does not require a relational model and at least suggests relational references include pointers.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for patent owner
“No other claim terms need construction for our decision here and we decline unnecessarily doing so. 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 15
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundUnpatentableDecided for petitioner
“We agree with Petitioner that the ordinarily skilled artisan would have been motivated to combine Rohall and Schiavone because Schiavone provides reasons to apply its techniques to email systems such as Rohall’s. Schiavone describes a need for “ensuring compliance of e-mail messages with applicable standards and/or laws and/or otherwise determining appropriateness of a message for an intended recipient,” especially because there is “a patchwork of local, federal and international laws.” Ex. 1006 ¶ 6. Schiavone also states that filtering emails, e.g., to remove spam, is beneficial. Id. ¶¶ 1–2. As Schiavone describes problems in email systems, which its rules-based email processing technique addresses, we determine that the ordinarily skilled artisan would have been motivated to combine Rohall and Schiavone. See KSR, 550 U.S. at 401 (a reference which teaches, suggests, or motivates its combination may “identify a reason that would have prompted a person of ordinary skill in the art to combine the elements”).” slip op. at 19
Patent outcomesUS 8,073,911 unpatentableClaim construction§ 103 obviousnesscites KSRPatents in suitUS 8,073,911 - Pgr2026-00044InstitutedPTAB · Sep 9, 2026 · PGR2026-00044 · APJ John A Squires · PGR · Institution
The Board granted PGR2026-00044 after finding the petition showed the required likelihood of prevailing on at least one challenged claim.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 12,359,506 - Ipr2026-00334InstitutedPTAB · Sep 9, 2026 · IPR2026-00334 · APJ John A Squires · IPR · Institution
The Director granted institution of IPR2026-00334 after finding a reasonable likelihood of prevailing on at least one challenged claim and no other non-discretionary reason to deny institution.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 12,231,703 - Ipr2026-00327OtherPTAB · Sep 9, 2026 · IPR2026-00327 · APJ John A Squires · IPR · Order
The notice lists IPR2026-00327 among proceedings granted institution after the petitioner showed the required likelihood of success.
RulingsOther- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 12,254,103 - Ipr2026-00314InstitutedPTAB · Sep 9, 2026 · IPR2026-00314 · APJ John A Squires · IPR · Institution
The Director granted institution of IPR2026-00314 after finding the petition showed a reasonable likelihood of prevailing on at least one challenged claim.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 11,066,656 - Ipr2026-00313InstitutedPTAB · Sep 9, 2026 · IPR2026-00313 · APJ John A Squires · IPR · Institution
The Director granted institution of IPR2026-00313 after finding a reasonable likelihood of prevailing on at least one challenged claim.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings:” slip op. at 2
NonePatents in suitUS 11,041,149 - Ipr2026-00312OtherPTAB · Sep 9, 2026 · IPR2026-00312 · APJ John A Squires · IPR · Order
The Director granted institution of IPR2026-00312 after finding the petitioner showed a reasonable likelihood of prevailing on at least one challenged claim.
RulingsOther- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings:” slip op. at 2
NonePatents in suitUS 10,865,400 - Ipr2026-00259InstitutedPTAB · Sep 9, 2026 · IPR2026-00259 · APJ John A Squires · IPR · Institution
The Director granted institution of IPR2026-00259 after finding the petitioner showed a reasonable likelihood of prevailing on at least one challenged claim and no non-discretionary consideration warranted denial.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 12,291,566 - Ipr2026-00258OtherPTAB · Sep 9, 2026 · IPR2026-00258 · APJ John A Squires · IPR · Order
Institution was granted in IPR2026-00258 because the petitioner showed a reasonable likelihood of prevailing on at least one challenged claim, and no non-discretionary consideration warranted denial.
RulingsOther- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 12,122,824 - Ipr2026-00257OtherPTAB · Sep 9, 2026 · IPR2026-00257 · APJ John A Squires · IPR · Order
The Director granted institution of IPR2026-00257 after finding the petition showed a reasonable likelihood of prevailing on at least one challenged claim.
RulingsOther- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pursuant 35 U.S.C. §§ 314(a) and 324(a), after review of the merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as appropriate, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review and post-grant review is granted in the following proceedings: IPR2026-00256 IPR2026-00312 IPR2026-00327 IPR2026-00257 IPR2026-00313 IPR2026-00334 IPR2026-00258 IPR2026-00314 PGR2026-00044 IPR2026-00259” slip op. at 2
NonePatents in suitUS 11,041,020
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.