• Uatp IP LLC v. Slick Slide LLCSome claims unpatentable
  PTAB · Oct 2, 2026 · PGR2024-00054 · APJ Brian D Range · PGR · Final written decision

  Claims 22–26 are unpatentable based on obviousness; claims 1–17, 27, and 28 were not shown unpatentable. Patent Owner’s motion to terminate was denied.

  RulingsFinal written decision

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

    “1. Mesh Layer Petitioner contends “no formal claim construction is necessary in this” slip op. at 13

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

    “5. Analysis On this complete record, we determine that Petitioner’s arguments do” slip op. at 31

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

    “form of nylon and some form of Teflon (and possible combinations thereof) having the specific coefficient of friction range given in limitation [1c] breaks down, because the building blocks of the obviousness argument are not sufficiently identified in Phillips alone, nor in the supporting testimony. Accordingly, we determine that Petitioner’s arguments and evidence fail to show that Phillips renders the challenged claims obvious. 6. Conclusion Based on the foregoing, we determine that Petitioner has not established by a preponderance of the evidence that claims 1–4, 6, and 7 would have been anticipated by or obvious in view of Phillips.” slip op. at 33

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

    “2. Products and Nexus We first consider the issue of whether certain evidence relied upon by” slip op. at 20

  Patent outcomesUS 11,998,854 mixed
  Claim construction§ 102 anticipation§ 103 obviousness§ 112 disclosurecites Phillips · Graham · Nautilus
  Patents in suitUS 11,998,854
• Shenzhen Tuozhu Technology Co., Ltd. v. Stratasys, Inc.All claims unpatentable
  PTAB · Sep 28, 2026 · IPR2025-00611 · APJ Christopher L Ogden · IPR · Final written decision

  Claims 1–10, 12, 13, 19, and 20 are unpatentable under § 103 over the stated Douglas–Mark and Hamilton-based grounds.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “The parties agree that experience could substitute for a degree, and vice versa. Pet. 3; PO Resp. 10. The parties’ proposed levels of ordinary skill are substantially similar. For this decision, as in the Institution Decision, we adopt Petitioner’s proposed level, which is supported by credible testimonial evidence and is consistent with the problems addressed in the ’774 patent. See Ex. 1001, 1:16–52. Our decision would be the same, however, if we were to adopt Patent Owner’s proposal.” slip op. at 7

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Other

    “Neither Petitioner nor Patent Owner argues that we need to construe any claim terms explicitly. See Pet. 2–3; PO Resp. 10. However, the parties contest two material claim-construction issues which we address below. To the extent that the parties’ positions depend on interpreting other claim language in a particular way, we discuss the relevant claim language below in the context of the parties’ arguments regarding the prior art.” slip op. at 8

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

    “We disagree with Patent Owner that a person of ordinary skill in the art would have understood that limitation 1.2 must be performed before limitations 1.3 or 1.4. See Ex. 1001, 35:21–24. See Interactive Gift Exp., Inc. v. Compuserve Inc., 256 F.3d 1323, 1342 (Fed. Cir. 2001) (“Unless the steps of a method actually recite an order, the steps are not ordinarily construed to require one.” (citing Loral Fairchild Corp. v. Sony Corp., 181 F.3d 1313, 1322 (Fed. Cir. 1999)). The evidence suggests that a “target printer” is any printer that is ultimately selected for fabricating the object, and such a printer could send its configuration information either before or after that determination is made in limitation 1.2. This interpretation does not render the word “target” meaningless. At some point, a printer must be determined to be the target printer, which is the one intended to ultimately fabricate the three-dimensional object. But the target printer still exists, and is capable of being queried, before that determination is made. We find the examples in the ’774 patent pertinent to this question. The ’774 patent states that “the target printer may include more than one printer.” Ex. 1001, 18:66–67. In discussing the step of “query target printer for properties 306” (Fig. 3A), the ’774 patent states that “[i]n one aspect, numerous queries are sent to numerous printers, e.g., for use in selecting one or more of the printers as the target printer.” Id. at 19:8–10. Alternatively, “the query is sent to a printer that is not necessarily the target printer as described herein, e.g., when the query or information received from a response to the query is used for the selection of the target printer.” Id. at 19:11–14. Importantly, the second embodiment states that the queried printer “is not necessarily the target printer,” suggesting that the queried printer could be the target printer even before it is determined to be such. Id. at 19:11–12 (emphasis added). Based on the evidence of record, a person of ordinary skill in the art would have understood that the “target printer” can be determined after the query recited in limitation 1.3 or the reception of configuration information recited in limitation 1.4. Thus, the evidence does not impose an ordering between limitations 1.2 and 1.3 or between limitations 1.2 and 1.4. The evidence also does not support Patent Owner’s argument that the two reverse-order examples in the ’774 patent are unclaimed embodiments.” slip op. at 10

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

    “We disagree that Petitioner’s arguments are based on impermissible hindsight, because they are based on the disclosures in Douglas and Mark, and Petitioner has articulated a persuasive reason to combine those references without referring to the ’774 patent itself, as we discuss below. See In re McLaughlin, 443 F.2d 1392, 1395 (CCPA 1971) (an obvious rationale is not improper hindsight if it “takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made and does not include knowledge gleaned only from applicant’s disclosure”).” slip op. at 29

  Patent outcomesUS 11,886,774 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,886,774
• Posco Co., Ltd. v. ArcelormittalAll claims unpatentable
  PTAB · Jul 16, 2026 · IPR2025-00371 · APJ Brian D Range · IPR · Final written decision

  Claims 1–25 are unpatentable as obvious under § 103 over the asserted combinations of Takagi, Cornette, Suehiro, GMW14400, Laurent, and Vaissiere.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner contends that a person of ordinary skill in the art (POSITA) “would have had an undergraduate degree in materials science, manufacturing engineering, mechanical engineering, or equivalent knowledge, training, or experience, with two years of experience working in metallurgy.” Pet. 6 (citing Ex. 1003 ¶ 15). Patent Owner does not challenge Petitioner’s definition of a POSITA for this proceeding. PO Resp. 8. Because the parties agree and because Petitioner’s proposal is reasonable and consistent with the ’227 patent specification and the prior art, we adopt Petitioner’s proposal. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art).” slip op. at 8

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

    “1. superficial layer The only independent claim at issue, claim 1, recites a “Superficial layer.” Ex. 1001, 15:6. Patent Owner argues that, based on plain and ordinary meaning, the term “superficial layer” refers to a “surface layer” or “top layer.” PO Resp. 8–9. Petitioner does not dispute this construction. See Pet. Reply 21–22 (arguing that the relevant layer of the Suehiro reference is a superficial layer because it is outermost and present at the surface). Because the parties are in agreement and because that agreement is consistent with plain language, claim language, and the ’227 specification, we construe “superficial layer” as referring to a surface layer or top layer.” slip op. at 10

  • Claim Construction › Extrinsic evidence (dictionaries, experts)Term construed petitioner constructionDecided for petitioner

    “defined stoichiometry” (Ex. 2037, 527) but the word may also be a “generic term for phases . . . which may have a narrow or extended compositional stability range” (id.). The first glossary meaning is consistent with Patent Owner’s position. The second, broader, glossary meaning is consistent with Petitioner’s position. Some of the extrinsic sources before us support the broad definition, and some support the narrow definition. See PO Sur-Reply 3–4 (arguing that Dr. Miles admitted that various treatises distinguish intermetallic compounds from alloys and solid solutions). Thus, neither Dr. Miles or Dr. Raabe is “wrong scientifically” in how they use the term “intermetallic” in this proceeding. Id. at 2 (noting that Dr. Miles agreed that Dr. Raabe’s construction is not wrong scientifically). As explained below, however, only one of these meanings is appropriate here. To decide which possible meaning applies to the ’227 patent, we focus on the patent claims and specification. Claim 1 indicates that the intermetallic layer has a “mean composition” (emphasis added). Ex. 1001, 15:1–10. This indicates, albeit weakly, that iron composition across the layer may vary rather than having ordered stoichiometry—consistent with Petitioner’s position. The specification also indicates that “intermetallic alloying” is a possibility—again, consistent with Petitioner’s position. Ex. 1001, 2:47–50. Meanwhile, nothing in the ’227 specification explicitly (or implicitly) suggests that “intermetallic layer” must be limited to elements atomically joined with defined stoichiometry in an ordered crystal structure. We also find that Dr. Miles’s testimony regarding the meaning of “intermetallic” is more credible than Dr. Rabbe’s testimony. Dr. Rabbe, in deposition, stated that Figure 2 of the challenged patent “does not show a layer that meets [his] construction of intermetallic.” Ex. 1078, 129:21–24. The ’227 patent, however, states that Figure 2 includes an “Al-rich Intermetallic layer.” Ex. 1001, Fig. 2, 3:60–64 (“FIG 2. Illustrates a coating … which does not correspond to the invention. This succession of layers (interdiffusion layer and intermetallic layer) yields inferior results in resistance spot welding.”). Also, Dr. Raabe previously referred to a layer of Takagi as having “intermetallic phase layering and structure.” Pet. Reply 4 (citing Ex. 1076 ¶ 166; Ex ¶ 1075, 17) (emphasis omitted). Thus, Dr. Raabe’s construction of “intermetallic” for this proceeding does not fully account for the ’227 patent usage of the word “intermetallic” and does not fully account for Dr. Raabe’s prior usage of the word “intermetallic.” Patent Owner argues that Petitioner’s construction “erases the meaningful distinction” between the claimed layers. PO Resp. 11. Patent Owner further argues that Petitioner’s construction renders the word “intermetallic” superfluous because allowing the intermetallic layer to be “merely a multi-element alloy erases the meaningful distinction among these layers.” Id. We disagree. The word intermetallic serves to require that the layer be composed of two or more metals or a metal and a metalloid. The word intermetallic also serves as a label to differentiate each of the four claimed layers. For example, in claim 1, the word “intermetallic” is used much like the words “interdiffusion” and “intermediate” to give each of the four layers (each having differently mean compositions) different labels.” slip op. at 16

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

    “Because IHS was a company that created an online database with the purpose of providing (selling) standards including General Motors standards to the public, we determine that a person of ordinary skill in the art would have known to look to this database and would have been able to find GMW14400. Patent Owner presents no evidence to the contrary. Because a preponderance of the evidence supports Petitioner, we determine Petitioner establishes GMW14400 is qualifies as prior art.” slip op. at 21

  Patent outcomesUS 11,326,227 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 11,326,227
• Posco Co., Ltd. v. ArcelormittalAll claims unpatentable
  PTAB · Jul 16, 2026 · IPR2025-00370 · APJ Brian D Range · IPR · Final written decision

  Claims 1–30 are unpatentable as obvious under § 103 over the asserted combinations of prior art.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner contends that a person of ordinary skill in the art (POSITA) “would have had an undergraduate degree in materials science, manufacturing engineering, mechanical engineering, or equivalent knowledge, training, or experience, with two years of experience working in metallurgy.” Pet. 6 (citing Ex. 1003 ¶¶ 13–16). Patent Owner does not challenge Petitioner’s definition of a POSITA for this proceeding. PO Resp. 8. Because the parties agree and because Petitioner’s proposal is reasonable and consistent with the ’602 patent specification and the prior art, we adopt Petitioner’s proposal. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art).” slip op. at 8

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

    “1. superficial layer All independent claims at issue, claims 1, 21, and 24, recite a “superficial layer.” Ex. 1001, 15:11, 16:60, 17:21. Patent Owner argues that, based on plain and ordinary meaning, the term “superficial layer” refers to a “surface layer” or “top layer.” PO Resp. 8–9. Petitioner does not dispute this construction. See Pet. Reply 21–22 (arguing that the relevant layer of the Suehiro reference is a superficial layer because it is outermost and present at the surface). Because the parties are in agreement and because that agreement is consistent with plain language, claim language, and the ’602 specification, we construe “superficial layer” as referring to a surface layer or top layer.” slip op. at 10

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

    “defined stoichiometry” (Ex. 2037, 527) but the word may also be a “generic term for phases . . . which may have a narrow or extended compositional stability range” (id.). The first glossary meaning is consistent with Patent Owner’s position. The second, broader, glossary meaning is consistent with Petitioner’s position. Some of the sources before us support the broad definition, and some support the narrow definition. See PO Sur-Reply 3–4 (arguing that Dr. Miles admitted that various treatises distinguish intermetallic compounds from alloys and solid solutions) Thus, neither Dr. Miles or Dr. Raabe is “wrong scientifically” in how they use the term “intermetallic” in this proceeding. Id. at 2 (noting that Dr. Miles agreed that Dr. Raabe’s construction is not wrong scientifically). As explained below, however, only one of these meanings is appropriate here. To decide which possible meaning applies to the ’602 patent, we focus on the patent claims and specification. The claims indicate that the intermetallic layer has a “mean iron composition” (emphasis added). Ex. 1001, 15:6–10. This indicates, albeit weakly, that the iron composition across the layer may vary rather than having ordered stoichiometry— consistent with Petitioner’s position. The specification also indicates that “intermetallic alloying” is a possibility—again, consistent with Petitioner’s position. Id. at 2:50–54. Meanwhile, nothing in the ’602 specification explicitly (or implicitly) suggests that “intermetallic layer” must be limited to elements atomically joined with defined stoichiometry in an ordered crystal structure. We also find that Dr. Miles’s testimony regarding the meaning of “intermetallic” is more credible than Dr. Raabe’s testimony. Dr. Raabe, in deposition, stated that Figure 2 of the challenged patent “does not show a layer that meets [his] construction of intermetallic.” Ex. 1078, 129:21–24. The ’602 patent, however, states that Figure 2 includes an “Al-rich Intermetallic layer.” Ex. 1001, Fig. 2, 3:57–61 (“FIG 2. Illustrates a coating . . . which does not correspond to the invention. This succession of layers (interdiffusion layer and intermetallic layer) yields inferior results in resistance spot welding.”). Also, Dr. Raabe previously referred to a layer of Takagi as having “intermetallic phase layering and structure.” Pet. Reply 4 (citing Ex. 1076, 166; Ex. 1075, 17) (emphasis omitted). Thus, Dr. Raabe’s definition of “intermetallic” does not fully account for the ’602 patent usage of the word “intermetallic” and does not fully account for Dr. Raabe’s prior usage of the word “intermetallic.” Patent Owner argues that Petitioner’s construction “erases the meaningful distinction” between the claimed layers. PO Resp. 11. Patent Owner further argues that Petitioner’s construction renders the word “intermetallic” superfluous because allowing the intermetallic layer to be “merely a multi-element alloy erases the meaningful distinction among these layers.” Id. We disagree. The word intermetallic serves to require that the layer be composed of two or more metals or a metal and a metalloid. The word intermetallic also serves as a label to differentiate each of the four claimed layers. For example, in claim 1, the word “intermetallic” is used much like the words “interdiffusion” and “intermediate” to give each of the four layers (each having differently defined mean iron compositions) different labels.” slip op. at 16

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

    “have had reason to combine teachings of Takagi and Cornette with a reasonable expectation of success. Pet. 11–20 (citing, e.g., Ex. 1003 ¶¶ 28– 42; Ex. 1016 ¶ 35; Ex. 1014, 9; Ex. 1025, 5:17–20; Ex. 1026, 7; Ex. 1034 ¶ 13). In particular, Petitioner argues that Takagi discloses a pre-coating thickness of 10–20 µm but does not explicitly disclose a post hot-stamping coating thickness corresponding to the pre-coating thickness. Pet. 11. Cornette teaches that the hot-stamping thickness causes coating expansion from 25 µm to about 40 µm, an increase of 60%. Id. (citations omitted). Petitioner and Dr. Miles reason that, when hot stamping Takagi’s product, the thickness would be 32 µm. Id. (citing Ex. 1003 ¶ 32); see also Pet. Reply 20–21. Thus, Patent Owner argues that Cornette evidences Takagi’s finally coating thickness without requiring modification of Takagi. Petitioner further argues that Takagi and Cornette teach that post hot- stamping thickness could be varied and optimized as a result effective variable. Id. at 12–13; see also Pet. Reply 17–18. Cornette teaches, for example, that “[t]he average [pre-coating] layer thickness showing the best compromise between corrosion protection and weldability is 25 µm” and links this pre-coating thickness to a final thickness of “about 40 µm at the steel surface.” Ex. 1014, 9. Petitioner also argues that it would have been obvious to fill in other details of Takagi including, for example, selecting USIBOR 1500 steel, based on the teachings of Cornette. Pet. 14. Patent Owner argues that there is no reason to combine Takagi with the teachings of Cornette. PO Resp. 26. Patent Owner makes seven related arguments. Patent Owner first argues that the Petitioner’s position is speculative and lacks basis. Id. at 26–27. We disagree. Cornette evidences a final coating thickness for Takagi, and the references also suggest that final coating thickness is result effective. Second, Patent Owner argues that there would have been no incentive to seek a motivation to seek a thicker coating post-hot stamping. Id. at 28– 35. This argument does not undermine Petitioner’s position that Takagi, by itself, would have reached a thicker coating after stamping as evidenced by Cornette. Pet. 11–12. Petitioner takes the position, with evidence, that practice of Takagi alone would reach the recited thickness. No motivation to modify Takagi is required under this position.” slip op. at 25

  Patent outcomesUS 10,961,602 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,961,602
• Google LLC v. Escapex IP LLCAll claims unpatentable
  PTAB · Mar 30, 2026 · IPR2025-00337 · APJ Justin T Arbes · IPR · Final written decision

  Claims 1–24 are unpatentable under § 103: claims 1–3, 5–6, 13–15, 17–18 over Fuloria and Andler; the remaining claims over combinations adding WO ’100, Bartholomew, Kirk, or Cheung.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “a person of ordinary skill in the art would have had “a bachelor’s degree in computer science or a similar field and three years of professional computer programming experience, including experience with networked media and databases, where additional education can substitute for experience or vice versa.” Pet. 20 (citing Ex. 1002 ¶¶ 27–31). In the Decision on Institution, Inst. 7–8. Patent Owner adopts Petitioner’s proposed definition “because it comports with the technology and claims of the ’687 [p]atent as well as the asserted prior art.” PO Resp. 4; Tr. 36:4–18. Based on the full record developed during trial, including our review of the ’687 patent and the types of problems and solutions described in the ’687 patent and cited prior art, we maintain the previously adopted definition of the level of ordinary skill in the art and apply it for purposes of this Decision.” slip op. at 9

  • Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed petitioner constructionDecided for petitioner

    “37 C.F.R. § 42.100(b). Petitioner argues that the term “engagement” in independent claims 1, 11–13, 23, and 24 is defined in the Specification of the ’687 patent and should be interpreted to mean “an indication that a user should be distinguished with respect to the content over another user.” Pet. 11 (citing Ex. 1001, col. 5, ll. 53–55; Ex. 1002 ¶ 41). Patent Owner agrees that the Specification “defines” the term in that manner. PO Resp. 13. The Board did not interpret any terms in the Decision on Institution. Dec. on Inst. 9. We agree with the parties’ proposed interpretation of “engagement” and apply it for purposes of this Decision, based on the Specification’s disclosure that “[a] user engagement with content refers to an indication that a user should be distinguished with” slip op. at 10

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

    “No other 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 [a particular claim limitation] where the construction is not ‘material to the . . . dispute.’” (emphasis added) (citation omitted)).” slip op. at 11

  • Expert testimonyPetitioner expert creditedDecided for petitioner

  Patent outcomesUS 10,474,687 unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,474,687
• Reolink Innovation Inc. / Shenzhen Reolink Technology Co., Ltd. v. Throughtek Co., Ltd.All claims unpatentable
  PTAB · Jan 23, 2026 · IPR2024-01192 · APJ Michael J Strauss · IPR · Final written decision

  Claims 1–10 and 16 are unpatentable as obvious over the asserted combinations of the Lorex Manual or Lorex Video with the identified references.

  RulingsFinal written decision

  • Novelty / Anticipation (§102) › Priority / effective filing date / continuation supportPriority date awardedDecided for petitioner

    “Patent Owner does not dispute any of Petitioner’s contentions as to the effective filing date, stating in agreement with Petitioner’s asserted Effective Filing Date of the Challenged Claims that “[t]he ’916 Patent claims a priority of a provisional application 61/924,240 filed on January 7, 2014.” PO Resp. 8. Given that the parties are in agreement on the January 7, 2014, effective filing date, we similarly use January 7, 2014, as the effective filing date of the challenged claims for purposes of this Decision.” slip op. at 4

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “II. ANALYSIS A. Level of Ordinary Skill in the Art Relying on the testimony of Vlad Kardashov, Petitioner proposes that a person of ordinary skill in the art at the time of the invention of the ’916 patent “would have had a bachelor’s degree in electrical engineering and two 7 US 2012/0198040 A1, published August 2, 2012 (Ex. 1011, “Kuo”). 8 The subject ’916 patent claims priority to Kuo as a continuation-in-part of that earlier filed application. Ex. 1001, code (63). 9 Lorex Technology Inc., “How to set up remote access for DVR using - Lorex Stratus Connectivity” (June 18, 2013), available at https://www. youtube.com/watch?v=fMPRi9WFuTM (Ex. 1012, the “Lorex Video”). 10 US 2012/0113265 A1, published May 10, 2012 (Ex. 1013, “Galvin”). years of work experience with network and communication technologies.” Pet. 8 (citing Ex. 1003 ¶¶ 12–14). Patent Owner does not contest Petitioner’s proposal or provide a proposal of its own. On the complete record, we adopt Petitioner’s description of the level of ordinary skill in the art, as it is consistent with the technology described in the ’916 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 8

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

    “Petitioner asserts that “no claim elements need a formal construction for purposes of resolving controversies in this proceeding.” Pet. 9 (citing Ex. 1003 ¶¶ 43–44; Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011), Google Inc. v. Intellectual Ventures II LLC, 701 Fed. Appx. 946, 956 (Fed. Cir. 2017)). Petitioner states “[a]ll claim terms should be construed according to the Phillips standard.” Id. (citing Phillips, 415 F.3d at 1303; 37 C.F.R. § 42.100). Patent Owner presents no proposed claim constructions. We determine that we need not expressly construe any claim terms to resolve the parties’ disputes on the current record. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’”) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)).” slip op. at 9

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityReference is prior artPriority date awardedDecided for petitioner

    “that Patent Owner fails to demonstrate that the Lorex Manual was based on a disclosure made by the inventor or joint inventor or by another who obtained the subject matter disclosed directly or indirectly from the inventor or a joint inventor. The Lorex Manual is relied on under Ground 1A, exclusively or in the alternative to or in combination with Kim, for all claim elements. Pet. 9– 31. Patent Owner fails to demonstrate that this subject matter was disclosed to Lorex by ThroughTek, much less by one of the inventors of the ’916 Patent.” slip op. at 22

  Patent outcomesUS 9,774,916 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,774,916
• Samsung Electronics Co., Ltd. v. CM HK LimitedInstituted
  PTAB · Dec 17, 2025 · IPR2025-01023 · APJ Benjamin D M Wood · IPR · Institution

  The Board instituted IPR on all asserted grounds against claims 1, 3, 7, and 9, finding a reasonable likelihood that Petitioner would prevail on at least one challenged claim.

  RulingsInstitution decision

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

    “c. Conclusion as to Claim 1 Having reviewed the record and the parties’ arguments, we determine that Petitioner has a reasonable likelihood of prevailing with respect to claim 1, and therefore has satisfied the threshold requirement for institution of inter partes review on the basis of Ground 1. 3. Claims 3, 7, and 9 Petitioner contends that Bassompiere teaches the limitations of claim 3, 7, and 9, and supports its contentions with citations to Bassompiere and to Dr. Sharrafzadeh’s declaration. Pet. 57–63. At this stage of the proceeding, Patent Owner does not raise any arguments specifically directed to these claims. “When instituting inter partes review, the Board will authorize the review to proceed on all of the challenged claims and on all grounds of unpatentability asserted for each claim.” 37 C.F.R. § 42.108(a). We must “either (1) institute as to all claims challenged in the petition and on all grounds in the petition, or (2) institute on no claims and deny institution.” CTPG at 5–6, 64; see also PGS Geophysical AS v. Iancu, 891 F.3d 1354, 1359–60 (Fed. Cir. 2018) (stating a decision to institute is “a simple yes-orno institution choice respecting a petition, embracing all challenges included in the petition”). Thus, because we have decided to grant institution on Ground 1 with respect to claim 1, we must do the same for claims 3, 7, and 9.” slip op. at 38

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Patent Owner does not offer any reason why we should deviate from the Board’s determinations in the prior IPRs that one of ordinary skill in the art would have had knowledge of Kalman filters and quaternion mathematics. Nor are we aware of any such reason. On the contrary, the Board’s prior determinations are consistent with the level of ordinary skill reflected by prior art of record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978). Bassompiere, for example, teaches using a data merging algorithm that is, “[a]dvantageously,” extended Kalman filtering. Ex. 1006, 4:17. Bassompiere also teaches using quaternions to determine a device’s pitch and roll about a horizontal reference frame. Id. at 6:3–8, 20:10–21:1. Nasiri teaches that quaternions can be used to represent a device’s “orientation in space.” Ex. 1008, 30:27– 30. Patent Owner argues that Dr. Sarrafzadeh’s testimony regarding the level of skill in the art in this proceeding contradicts his testimony in the prior IPRs, which did not include knowledge of Kalman filters and quaternion mathematics in his definition of the level of ordinary skill in the art. Prelim. Resp. 24–26. Patent Owner asserts that this contradiction “undermin[es] his credibility.” Id. at 26. We disagree. The testimony Dr. Sarrafzadeh provided in the earlier IPRs obviously preceded the Board’s determinations in those proceedings that, on the whole record, including the testimony of then-Patent Owner’s declarant, the level of ordinary skill included knowledge of Kalman Filters and quaternions. Dr. Sarrafzadeh’s testimony in this proceeding reasonably aligns with those determinations. Accordingly, for the above reasons, we adopt Petitioner’s definition of the level of ordinary skill in the art for purposes of this Decision.” slip op. at 13

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “We disagree with Patent Owner’s characterization. The teaching to use quaternions instead of Euler angles comes from Bassompiere, not Dr. Sarrafzadeh. See Ex. 1006, 20:10–11 (“A first variant embodiment consists in replacing the angles of torsion θ and ψ by a quaternion formulation of the same torsion.”). Rather than supplying a missing limitation, we understand Dr. Sarrafzadeh to be explaining how a person of ordinary skill in the art would have implemented Bassompiere’s teaching to use quaternions instead of Euler angles given that person’s knowledge of quaternion mathematics. Patent Owner also argues that “switching from Euler angles to quaternions is not a routine substitution but requires the reengineering of the EKF.” Prelim. Resp. 28. Patent Owner similarly contends that Dr. Sarrafzadeh “devotes nearly twenty pages of his declaration to rewriting Bassompiere’s Euler-based equations ‘in quaternion form,’ and explaining how to convert them back to Euler angles,” and notes that “[a]s other researchers in the field have confirmed, ‘[w]hile implementing orientation tracking using quaternions provides advantages like avoiding gimbal lock, it is significantly more complex than the Kalman filer using Euler angles.’” Prelim. Resp. 32–33 (citing Ex. 1002, 31–51; quoting Ex. 2027, 1). Patent Owner thus contends that replacing Euler angles with quaternions “is not a ‘trivial’ substitution.” Id. at 33. But Petitioner does not appear to be arguing that replacing Euler angles with quaternions would have been “trivial” or simple, only that doing so was taught by Bassompiere and within the knowledge and capabilities of a person of ordinary skill in the art. We determined above that a skilled artisan had knowledge of extended Kalman filters and quaternion mathematics such knowledge, and we are required to consider the knowledge and capabilities of a person of ordinary skill in our analysis. Further, at this preliminary stage, Patent Owner’s assertion that the Euler angle/quaternion switch would not have been a routine substitution is supported only with attorney argument, which is entitled to no weight. Icon Health & Fitness, Inc. v. Strava, Inc. 849 F.3d 1034, 1043 (Fed. Cir. 2017). As such, it does not outweigh Dr. Sarrafzadeh’s contrary testimony. See, e.g., Ex. 1002 ¶ 56.” slip op. at 30

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

    “The parties agree that the claimed “spatial reference frame” is associated with a device, has its origin at the same point in the device, and has axes that are always fixed with respect to the device. The only disagreement is whether that device is a “3D pointing device” or an “electronic device.” The Specification indicates that “electronic device” encompasses 3D pointing devices as well as, e.g., smartphones and navigation equipment, and therefore is the broader term. Ex. 1001, 8:35–39. At this stage of the proceeding, we determine that the threshold question of institution can be decided under either construction, because Patent Owner does not dispute that the primary asserted reference, Bassompiere, teaches a “spatial reference frame” associated with a 3D pointing device. Pet. 30–31. Therefore, at this stage of the proceeding, we decline to resolve the parties’ dispute. See Vivid Techs., Inc. v. Am. Sci. & Eng'g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those [claim] terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.”); Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (approving Board decision not to construe claim language where the construction is not material to the dispute).” slip op. at 15

  Claim construction§ 103 obviousnessDiscretionary denialcites Phillips · KSR · Graham
  Patents in suitUS 10,852,846
• Reolink Innovation Inc. / Shenzhen Reolink Technology Co., Ltd. v. Throughtek Technology (Shenzhen) Co., Ltd. And Throughtek Co., Ltd.All claims unpatentable
  PTAB · Dec 15, 2025 · IPR2024-01193 · APJ David C Mckone · IPR · Final written decision

  Claims 1–3, 5, 7–13, 15–19, and 23–25 are unpatentable: claims 1, 7, 8, 10, 11, 15, 16, 18, 19, and 23–25 as anticipated by Zhang; all challenged claims also as obvious over at least one …

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “person of ordinary skill in the art “would have had a bachelor’s degree in electrical engineering and two years of work experience with network and communication technologies.” Pet. 5 (citing Ex. 1003 ¶¶ 13–15). Patent Owner does not contest Petitioner’s proposal or provide a proposal of its own. On the complete record, we adopt Petitioner’s description of the level of ordinary skill in the art, as it is consistent with the technology described in the ’448 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 11

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededTerm construed board ownMixed

    “construction of “feature flag” is inconsistent with the language of claim 8, which states that “the feature flag indicates that the running state of the second apparatus is the sleep state.” Petitioner also argues that Patent Owner’s proposal is not supported by claim 24, which depends from claim 23 and states that “the feature flag is located at a header of the sleep login packet.” Id. at 3. We agree with Petitioner. The plain language of claim 8 states what a feature flag indicates. Claim 24 recites where the feature flag is located. Neither claim suggests any of Patent Owner’s additional limitations.” slip op. at 13

  • Expert testimonyPetitioner expert creditedDecided for petitioner
  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable

    “[A] prior art reference will anticipate if it ‘disclose[s] each and every element of the claimed invention . . . arranged or combined in the same way as in the claim.’” Blue Calypso, LLC v. Groupon, Inc., 815 F.3d 1331, 1341 (Fed. Cir. 2016) (quoting In re Gleave, 560 F.3d 1331, 1334 (Fed. Cir. 2009) (alteration by Federal Circuit)). “However, a reference can anticipate a claim even if it ‘d[oes] not expressly spell out’ all the limitations arranged or combined as in the claim, if a person of skill in the art, reading the reference, would ‘at once envisage’ the claimed arrangement or combination.” Id. (quoting Kennametal, Inc. v. Ingersoll Cutting Tool Co., 780 F.3d 1376, 1381 (Fed. Cir. 2015) (alteration by Federal Circuit); In re Petering, 301 F.2d 676, 681 (CCPA 1962)). For the reasons explained below, we are persuaded that Petitioner has shown, by a preponderance of the evidence, that claims 1, 7, 8, 10, 11, 15, 16, 18, 19, and 23–25 are anticipated by Zhang. slip op. at 16

  Patent outcomesUS 10,602,448 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · Graham
  Patents in suitUS 10,602,448
• Reolink Innovation Inc. / Shenzhen Reolink Technology Co., Ltd. v. Throughtek Co. Ltd.Instituted
  PTAB · Dec 12, 2025 · IPR2025-01327 · APJ Sheila F Mcshane · IPR · Institution

  The Board instituted IPR of claims 1–19 on all asserted grounds, finding a reasonable likelihood of prevailing on the Schwan-Lee and Schwan-Lee-Strickland obviousness grounds.

  RulingsInstitution decision

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

    “partes review. See 35 U.S.C. § 314; 37 C.F.R. § 42.4(a). Under 35 U.S.C. § 314(a), we may not authorize an inter partes review unless the information in the petition and the preliminary response “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons stated below, we determine that Petitioner has established a reasonable likelihood that it would prevail with respect to at least one claim. We therefore institute inter partes review as to all of the challenged claims of the ’655 patent and all of the asserted grounds of unpatentability in the Petition.” slip op. at 2

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “III. ANALYSIS A. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art: would have had a bachelor’s degree in electrical engineering, computer engineering, computer science, or equivalent, and two years of work experience with network devices and communication technologies. EX1003, ¶¶17–19. Additional education might compensate for less experience, and vice versa. Pet. 4 (citing Ex. 1003 ¶¶ 17–19).” slip op. at 6

  • Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed board ownDecided for petitioner

    “The ’655 patent Specification states that: The topology data table 21 of the online server 20 is mainly recorded with a link data 49 between each of the P2P devices 41– 46 within the P2P device community. The link data 49 refers to the connection relationship between the P2P devices 41–46, which includes, but is not limited to, the connection structure, connection data and/or locations of connection. Ex. 1001, 4:51–57. On this preliminary record, we agree with Petitioner that the term “link data” is a “connection relationship between the P2P devices.” This meaning is consistent with the ordinary meaning of the term within the context of the claim, that is, “link data” means data on the links (connections) between each of the P2P devices, where the Specification provides a more fulsome meaning that the term includes, at least, “the connection structure, connection data and/or locations of connection.” See id. at 4:55–57. We invite the parties to provide additional briefing on the construction of this term during trial.” slip op. at 8

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

    “Lee discloses that the P2P overlay is generated with the overlay generation unit 220 that generates the P2P overlay by analyzing information regarding “the corresponding application service, the peer, and the network,” where the network information “may include a network topology, a maximum bandwidth, a current network usage, [and] a transmission delay time, and the like.” Ex. 1005 ¶ 54. We determine that this disclosure provides support for Mr. Lett’s testimony that “Lee describes techniques for changing an overlay in response to changing network characteristics,” which could be beneficial. Ex. 1003 ¶ 48. Accordingly, on this preliminary record, we find this evidence is sufficient to support a rationale to combine Schwan and Lee. See KSR, 550 U.S. at 401 (“[I]f a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious.”).” slip op. at 13

  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,727,655
• Arashi Vision (U.S.) LLC (D/B/A Insta360) v. Gopro, Inc.No claims unpatentable
  PTAB · Dec 10, 2025 · IPR2024-01186 · APJ Brian D Range · IPR · Final written decision

  Claims 1–20 were not shown unpatentable because Kwatra does not teach or suggest minimizing rotational velocity and acceleration as required by the claims.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner contends that a person of ordinary skill in the art (POSITA) would have the following characteristics: “a bachelor’s degree in engineering or computer science, or equivalent field, and two years of experience working on image or video processing or digital cameras.” Pet. 6 (citing Ex. 1002 ¶¶ 36–37). Petitioner states that, “[a]lternatively, a POSITA would have four years of experience working on image or video processing 6 Patent Owner asserts objective evidence of nonobviousness. Prelim. Resp. 19–27. or digital cameras.” Id. Petitioner further contends “[a]n advanced graduate degree in the disciplines cited above may make up for the work experience indicated above.” Id. Patent Owner does not dispute the level of ordinary skill in the art. Prelim Resp. 14–15. For purposes of this Decision, we adopt Petitioner’s proposal as reasonable and consistent with the ’894 patent specification and the prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art).” slip op. at 10

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

    “Petitioner “does not believe any terms require a formal construction.” Pet. 6. Patent Owner agrees “no claim terms presently require construction to resolve any current dispute between the parties.” PO Resp. 15. We do not discern a need to construe explicitly any claim language at this juncture because doing so would have no effect on our analyses below of Petitioner’s asserted grounds and will not assist in resolving the present controversy between the parties. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’”) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)).” slip op. at 11

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

    “Kwatra teaches, at Equation 7, minimizing velocity and acceleration of a function representing camera path (P). FF ¶¶ 6, 8–9. Kwatra does not state that this camera path function considers rotation. Rather, the words “camera path” suggest x, y, z movement of the camera rather than rotation of the camera. Dr. Foroosh’s testimony that Kwatra’s minimization of a smoothed camera path does not result in minimizing rotational velocity and acceleration is credible because this testimony is consistent with Kwatra as a whole and consistent with the other evidence of record. Id. ¶ 10. Kwatra recognizes that image rotation angle (“θ”) may not remain smooth. Id. ¶ 12. But rather than attempting to minimize velocity and acceleration of rotation of the camera housing, Kwatra states that applying a smoothness constraint on rotation angle “may be non-linear.” Id. ¶ 13. Consistent with Kwatra, Dr. Foroosh credibly explains the difficulty of applying linear techniques to rotation. Id. Thus, Kwatra proposes instead constraining the sine and cosine of theta. Id. ¶ 14. The Kwatra provisional application is part of the Kwatra reference (id. ¶ 15), and it similarly opts for simpler schemes rather than estimating all parameters for all frames jointly. Id. ¶ 16. The provisional explains that the rotational component is relatively small such that non-linear computations minimizing velocity and rotation can be avoided. Id. ¶¶ 17–18. The testimony of Patent Owner’s witness, Dr. Foroosh, explaining the provisional is credible (Ex. 2018 ¶ 72) because it is consistent with Kwatra’s complete disclosure. Dr. Foroosh’s testimony is more credible than the testimony of Petitioner’s witness, Dr. Katsaggelos, because Dr. Katsaggelos did not review the Kwatra provisional application and, thus, did not review the entire disclosure of Kwatra. Id. ¶ 19; see also In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985) (en banc) (obviousness analysis considers whether “the claimed inventions are rendered obvious by the teachings of the prior art as a whole” (emphasis added)).” slip op. at 28

  • Expert testimonyPatent owner expert creditedPetitioner expert discountedDecided for patent owner

    “(id. ¶ 15), and it similarly opts for simpler schemes rather than estimating all parameters for all frames jointly. Id. ¶ 16. The provisional explains that the rotational component is relatively small such that non-linear computations minimizing velocity and rotation can be avoided. Id. ¶¶ 17–18. The testimony of Patent Owner’s witness, Dr. Foroosh, explaining the provisional is credible (Ex. 2018 ¶ 72) because it is consistent with Kwatra’s complete disclosure. Dr. Foroosh’s testimony is more credible than the testimony of Petitioner’s witness, Dr. Katsaggelos, because Dr. Katsaggelos did not review the Kwatra provisional application and, thus, did not review the entire disclosure of Kwatra. Id. ¶ 19; see also In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985) (en banc) (obviousness analysis considers whether “the claimed inventions are rendered obvious by the teachings of the prior art as a whole” (emphasis added)).” slip op. at 28

  Patent outcomesUS 10,574,894 not shown unpatentable
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,574,894

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.