- Google LLC v. Withrow Networks Inc.All claims unpatentablePTAB · 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 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,771,849 - Netflix, Inc. v. Divx, LLCAll claims unpatentablePTAB · Sep 21, 2026 · IPR2020-00558 · APJ Kevin F Turner · IPR · Remand
Claims 1–24 are unpatentable as obvious over Chen, Lindahl, and Hurst because the combination teaches the claim limitations and has motivation to combine and a reasonable expectation of success.
RulingsRemand decision- RemandOther
“On February 13, 2026, the Federal Circuit issued a decision in the appeal vacating the Second Final Decision as to all challenged claims and remanding for further proceedings. Netflix II, 7. The Federal Circuit reversed the Board’s claim construction, vacated the Board’s decision, and remanded for further proceedings consistent with the claim construction the 6 The First Final Decision also addressed Petitioner’s Motion to Exclude (Paper 42), where we granted-in-part, denied-in-part, and dismissed-in-part that Motion. See 1st Final Dec. 28–37. Our determinations on that Motion were a part of Petitioner’s appeal to the Federal Circuit. See Paper 52. As the Federal Circuit did not address this aspect of the First Final Written Decision, we determine our conclusions with respect to that Motion remain undisturbed. Federal Circuit adopted. Id. The Federal Circuit issued its mandate on March 23, 2026.” slip op. at 4
- Skill levelSkill level petitioner adoptedDecided for petitioner
“person of ordinary skill in the art at the time of the invention (“POSITA”) would have had “a bachelor’s degree in mechanical engineering, electrical engineering, computer science, or a similar field with at least two years of experience in video streaming and media security or . . . a master’s degree in mechanical engineering, electrical engineering, computer science, or a similar field with a specialization in video streaming and media security.” Pet. 14–15 (citing Ex. 1003 ¶¶ 65–67). Patent Owner does not refute Petitioner’s assessment and appears to apply such a level of skill in its arguments against combining Chen, Lindahl, and Hurst to teach or suggest the elements of the challenged claims. See generally PO Resp. As such, we continue to adopt and apply Petitioner’s unopposed position as to the level of ordinary skill in the art for purposes of this decision. See Inst. Dec. 6; 1st Final Dec. 6; 2nd Final Dec. 10.” slip op. at 7
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“In response, we conclude that the most natural reading of limitation [l] results from examination of the entire limitation: “locating encryption information that identifies encrypted portions of frames of video within the requested portions of the selected stream of protected video.” Ex. 1001, 27:54–57. The “within” most naturally connotes where the encrypted portions of frames of video occur, as opposed to determining where the encryption information may be located. Patent Owner’s interpretation is not wrong, i.e., the limitation could be read as Patent Owner suggests, leading to a narrower construction, but we are not persuaded that the construction of limitation [l] must be so limited, on the basis of the words themselves. We continue to reject Patent Owner’s interpretation that limitation [l] requires locating encryption information within the requested portions of the selected stream of protected video. See Inst. Dec. 27–30; 1st Final Dec. 8. Although it is apparent that encryption information can be found within the requested portions, we are not persuaded that the claim language or ’588 Patent implicitly or explicitly requires such a relationship. Likewise, although embodiments disclosed in the Specification of the ’588 Patent are consistent with Patent Owner’s more restrictive construction, the Specification also is consistent with the more grammatically correct construction as well. Thus, we construe limitation [l] as requiring that the encrypted portions of frames of video be within the requested portions of the selected stream of protected video, but we do not construe limitation [l] as requiring that the encryption information be within the requested portions of the selected stream of protected video.” slip op. at 15
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner
“We are persuaded that the Petition demonstrates that one of ordinary skill in the art would have had a motivation to combine Chen, Lindahl, and Hurst, as asserted by Petitioner. As the Federal Circuit found, the Petition pointed to and relied upon the portions in Chen describing pre-Chen art, without scalability or FEC features that were part of what Chen describes as aspects of its own inventive system. Netflix I, slip op. at 9–10 (citing Pet. 17–19, 69–70). We agree with Petitioner that “Chen-924 teaches several embodiments that adaptively stream alternative representations of a video using partially encrypted container files.” Pet. 20 (citing Ex. 1010, 14:41–15:60). We determine that Chen-924 provides support for the rationale provided in the Petition, and that one of ordinary skill in the art would have been motivated to combine Chen and Lindahl in view of the disclosure of Chen-924. As discussed above, the Petition does not rely solely on privacy concerns and improvements to efficiency as its motivation to combine the references. See Pet. 18–19 (specifying piracy concerns, improvements to the efficiency of adaptive streaming, optimization of the balance between bitrate and bandwidth, and improvements to the end-user experience with fast startup and seek). With respect to whether one of ordinary skill in the art would have” slip op. at 30
Patent outcomesUS 10,225,588 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,225,588 - ARM Ltd v. Daedalus Prime LLCAll claims unpatentablePTAB · Sep 9, 2026 · IPR2025-00207 · APJ Gregg I Anderson · IPR · Final written decision
Claims 1–7, 11–14, and 16–19 are unpatentable as obvious over the asserted grounds.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“would have (1) at least a bachelor’s degree in electrical engineering, computer engineering, physics, or a similar field, and (2) approximately two years of industry or academic experience in a field related to microelectronic architecture design, including experience with cache management in multicore systems-on-a-chip (SoCs). (Ex-1003 ¶¶50-51.) More related education would compensate for fewer years of work experience (and vice versa). (Ex-1003 ¶¶50-51.) Pet. 4–5. This definition was adopted in the Institution Decision. Inst. Dec. 13. Patent Owner does not dispute the finding. PO Resp. 5–6. For the purpose of our Decision, we maintain the finding made in the Institution Decision.” slip op. at 15
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner
“1. “a single caching agent” (claim 1) We note a construction issue from the ’1344 IPR where we construed a “single caching agent,” which is recited in claim 1 here. ’1344 IPR Final Decision, 16–18. We concluded that a “‘single caching agent’ means ‘one caching agent for the processor, which may be formed from distributed portions.’” Id. at 18. We adopted that construction in our Institution Decision in this case. Inst. Dec. 15.” slip op. at 16
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“2. Remaining claim terms Independent claims 11 and 16 include different language as to “caching agent.” Claim 11 recites “a caching agent.” Ex. 1001, 8:18. Claim 16 similarly recites “a first caching agent.” Id. at 8:47–48. Neither claims 11 or 16 includes claim 1’s recitation of “distributed portions. The “caching agent” limitations of claims 11 and 16, are not at issue. Accordingly, no construction is necessary.” slip op. at 18
- PTAB / AIA Trials › §315(e) estoppelEstoppel appliesDecided for petitioner
“(1) the issue is identical to one decided in the first action; (2) the issue was actually litigated in the first action; (3) resolution of the issue was essential to a final judgment in the first action; and (4) plaintiff had a full and fair opportunity to litigate the issue in the first action. Pet. Br. 2. Further, Petitioner alleges the ’1344 Final Decision was not appealed by Patent Owner and is therefore a basis for issue preclusion. Id. (citing Power Integrations, Inc. v. Semiconductor Components Indus., LLC, 926 F.3d 1306, 1311–12 (Fed. Cir. 2019)).” slip op. at 19
Patent outcomesUS 8,984,228 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,984,228 - Apple Inc. v. Varia Holdings LLCAll claims unpatentablePTAB · Feb 27, 2026 · IPR2024-01364 · APJ Norman H Beamer · IPR · Final written decision
Claims 1–39 are unpatentable under § 103 over Willgert and Mooney; claims 3–9, 15–19, 22–28, and 34–38 are also unpatentable over Willgert, Mooney, Holloway, and Pitroda.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“Based on a review of the record, we adopt Patent Owner’s proposed level of ordinary skill in the art, with its inclusion of a Computer Science background, because it is consistent with the evidence of record, including the asserted prior art and ‘984 patent specification. Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). However, our Decision would not be altered if Petitioner’s definition applied.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“d) Analysis Re Construing “Voice Call Signals” We conclude that it is unnecessary to define “voice call signal.” Patent Owner’s construction would read into the term additional limitations that are for the most part already set forth in the claims: “a switchable mobile communications device capable of . . . voice call communication” (claims 1, 13, 21, 32); “output . . . a voice call signal for transmission . . . over a wireless network” (claims 13, 21, 32); “wherein the mobile communication device is a selected one of a wireless mobile phone and a personal digital assistant equipped with communication capability” (claims 12, 20, 31, 39). Thus the claims require a mobile communications device that is capable of communicating a voice call signal, but do not restrict the voice call signal to only be communicated by a mobile communications device. Likewise, claims 13, 21, and 32 (but not claim 1) require the voice call signal to be transmitted over a wireless network, but do not restrict transmission to only a wireless network, and do not restrict the wireless network to “a network of a wireless network service provider,” as Patent Owner would require.” slip op. at 15
- Claim Construction › Intrinsic evidence (Phillips canons) › Specification disavowal / 'present invention' languageTerm construed board ownDisclaimer not foundDecided for petitioner
“construction for the RFID transponder signal or data terms — it is sufficient for purposes here to conclude that the claims encompass Petitioner’s “functional emulation” articulation. See Reply 11–12. That is, the purpose of the frequent references to “emulated,” “emulation,” or the like in the ‘984 patent is to emphasize the fact that the mobile communications device of the claims has a dual role: to provide voice call communications, and to transmit RFID transponder data. In the latter role, transmitted RFID transponder data appears to an RFID reader to have been transmitted from an ordinary RFID transponder. But there is no need to rewrite the claims to restore the emulation terms, given that, as we discuss further below, Patent Owner deliberately removed those terms during prosecution. The functional emulation implicit in the ‘984 specification and claims” slip op. at 22
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“the fact that Willgert teaches that integrating its communications unit into a mobile telephone designed for Bluetooth communication was a “highly user-friendly application,” and that it was well known practice to use a Bluetooth headset wirelessly communicating with the phone to enable hands-free phone calls, as specifically taught by Mooney. Pet. 12–14 (citing Ex. 1004 ¶¶ 8, 30–32; Ex. 1005, Fig. 3, ¶¶ 7, 39, 46–48; Ex. 1021; Ex. 1003 ¶¶ 72–76). Petitioner further argues that Bluetooth headsets were widely available, that incorporating the headset involved known methods yielding predictable results, and that one of ordinary skill would have reasonably expected to succeed in combining the teachings of Willgert and Mooney. Id. at 15–16 (citing Ex. 1004 ¶¶ 8, 10; Ex. 1005, ¶ 8; Ex. 1017, 1, 3; Ex. 1021, 2; Ex. 1003 ¶¶ 77–79). Patent Owner does not specifically address the issue of motivation to combine Willgert and Mooney. See generally PO Resp. We find, based on the record, that Petitioner has proved by a preponderance of the evidence that a person of ordinary skill in the art would have been motivated to combine Willgert and Mooney as proffered by Petitioner with a reasonable expectation of success.” slip op. at 31
Patent outcomesUS 8,127,984 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 8,127,984 - Apple Inc. v. Varia Holdings LLCAll claims unpatentablePTAB · Feb 27, 2026 · IPR2024-01363 · APJ Norman H Beamer · IPR · Final written decision
Claims 1–32 are unpatentable under § 103 over Willgert and Mooney, or Willgert, Mooney, Holloway, and Pitroda, as applicable.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“Patent Owner “disputes the narrow range of educational experiences in the Petition’s POSITA definition, but does not otherwise dispute the remaining portion of the definition.” PO Resp. 13. Patent Owner contends that person of ordinary skill in the art: [W]ould have been someone “with at least a Bachelor’s degree in Electrical Engineering, Computer Science, or a related field, with a background in radio frequency communications and software development, as well as approximately two years of experience working with or researching radio frequency communication systems. Lack of work experience can be remedied by additional education, and vice versa.” PO Resp. 13–14 (citing Ex. 2004 ¶ 34).7 Based on a review of the record, we adopt Patent Owner’s proposed level of ordinary skill in the art, with its inclusion of a Computer Science background, because it is consistent with the evidence of record, including the asserted prior art and ’947 patent specification. Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). However, our Decision would not be altered if Petitioner’s definition applied.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Not reached
“d) Analysis Re Construing “Voice Call Signals” We conclude that it is unnecessary to define “voice call signal.” Patent Owner’s construction would read into the term additional limitations that are for the most part already set forth in the claims: “the voice call signal is output over a wireless network” (claims 1 ); “outputting the voice call signal over a wireless network” (claim 9); “output a voice call signal for transmission over a wireless network” (claim 16); transmit voice call signals . . . over a wireless network” (claim 26); “wherein the mobile communication device is one of a wireless mobile phone and a personal digital assistant equipped with communication capability” (claims 8, 15, 25, 32). Thus the claims require the voice call signal to be transmitted over a wireless network, but do not restrict transmission to only a wireless network, and do not restrict the wireless network to “a network of a wireless network service provider,” as Patent Owner would require. We also agree that there is nothing in the ’984 prosecution history that supports Patent Owner’s assertion that the Examiner found that the Bluetooth signal of Cooper was not a voice call signal. Cooper was distinguished because: The term “transceiver,” however, is well understood by those of ordinary skill in the art. One of ordinary skill in the art would not reasonably interpret a “transceiver” so broadly as to incorporate an entire mobile device’s circuitry, and in particular to be read on by two separate transmitters, as Cooper teaches. Ex. 1008, 40. On the other hand, we agree with Patent Owner that Petitioner’s” slip op. at 14
- Claim Construction › Intrinsic evidence (Phillips canons) › Specification disavowal / 'present invention' languageTerm construed petitioner constructionDecided for petitioner
“This functional emulation solution is served regardless of how the specific RFID transceiver is implemented — the ’947 specification specifically provides for both software and hardware implementations. Id. at 2:24–28 (“Embodiments of the present invention includes . . . certain hardware and/or software embodied therein for the practice of the emulated RFID method”), 3:35–36 (“mobile communication device 102 is equipped with hardware and/or software elements”), 3:52–54 (“substantial portions of the hardware and/or software elements employed to provide a RFID”), 5:16 (“A Hardware/Software Implementation”). There is no reason why one version of the hardware used to emulate the RFID function could not be RFID transponder circuitry. The issue is not whether an RFID transponder can emulate itself, but rather whether RFID transponder circuitry incorporated into a mobile communications device can be used to allow the mobile communications device to emulate a separate RFID transponder. For example, rather than requiring the person described in the Background of the ’947 patent to carry both a mobile phone and a “key with remote control for gaining access to his/her vehicle,” they need only carry the mobile communications device of the claims. The statement in the ’947 patent that “the present invention is related to an emulated radio frequency data input method” (Ex. 1001, 1:22–24), and the other references to emulation, are consistent with a conclusion that the claims encompass the “functional emulation” option as described above. However, there is no basis for adding the negative limitation proposed by Patent Owner (“without the use of a physical RFID transponder”). Omega Engineering, 334 F.3d at 1333 (rejecting a construction because “neither the plain text of the claims, the specification, nor the file wrapper justifies the imposition of this negative limitation”). See also BillJCo, LLC v. Apple Inc., No. 2023-2189, 2023-2190, 2025 WL 1417957, at *1 (Fed. Cir. May 16, 2025): Our court has “identified claim constructions that exclude a particular element as including a ‘negative limitation’ and held that such exclusions must find support either in ‘the words of the claim’ or through an ‘express disclaimer or independent lexicography in the written description that would justify adding that negative limitation.’” Ethicon LLC v. Intuitive Surgical, Inc., 847 F. App’x 901, 907 (Fed. Cir. 2021). Moreover, the prosecution history of the ’984 grandfather patent is not” slip op. at 22
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“Petitioner argues that this combination would have been motivated by the fact that Willgert teaches that integrating its communications unit into a mobile telephone designed for Bluetooth communication was a “highly user- friendly application,” and that it was well known practice to use a Bluetooth headset wirelessly communicating with the phone to enable hands-free phone calls, as specifically taught by Mooney. Pet. 16–18 (citing Ex. 1004 ¶¶ 8, 30, 32; Ex. 1005, Fig. 3, ¶¶ 7, 39, 48; Ex. 1021; Ex. 1003 ¶¶ 62–65). Petitioner further argues that Bluetooth headsets were a well-known concept and widely available, that incorporating the headset involved known methods yielding predictable results, and that one of ordinary skill would have reasonably expected to succeed in combining the teachings of Willgert and Mooney. Id. at 19–21 (citing Ex. 1004 ¶¶ 8, 10, 30; Ex. 1005, ¶ 8; Ex. 1016; Ex. 1017, 1, 3; Ex. 1021, 2; Ex. 1003 ¶¶ 66–68). Patent Owner does not specifically address the issue of motivation to combine Willgert and Mooney. See generally PO Resp. We find, based on the record, that Petitioner has proved by a preponderance of the evidence that a person of ordinary skill in the art would have been motivated to combine Willgert and Mooney as proffered by Petitioner with a reasonable expectation of success.” slip op. at 29
Patent outcomesUS 9,405,947 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 9,405,947 - Apple Inc. v. Varia Holdings LLCAll claims unpatentablePTAB · Feb 27, 2026 · IPR2024-01362 · APJ Norman H Beamer · IPR · Final written decision
Claims 1–19 are unpatentable under § 103 over Willgert and Mooney, or over Willgert, Mooney, Holloway, and Pitroda for claims 3–6, 10, 11, and 13–17.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“Patent Owner “disputes the narrow range of educational experiences in the Petition’s POSITA definition, but does not otherwise dispute the remaining portion of the definition.” PO Resp. 12. Patent Owner contends that person of ordinary skill in the art: [W]ould have been someone “with at least a Bachelor’s degree in Electrical Engineering, Computer Science, or a related field, with a background in radio frequency communications and software development, as well as approximately two years of experience working with or researching radio frequency communication systems. Lack of work experience can be remedied by additional education, and vice versa.” PO Resp. 12 (citing Ex. 2004 ¶ 34).7 Based on a review of the record, we adopt Patent Owner’s proposed level of ordinary skill in the art, with its inclusion of a Computer Science background, because it is consistent with the evidence of record, including the asserted prior art and ’974 patent specification. Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). However, our Decision would not be altered if Petitioner’s definition applied.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“We agree with Patent Owner’s description of the characteristics and operation of a wireless mobile phone, which are not in dispute. Also, the Specification’s description of wireless mobile phones is relied on by Patent Owner in its arguments regarding the construction of “voice call signal,” as discussed below. Nonetheless, Petitioner argues that it is unnecessary to construe the term, “wireless mobile phone.” Reply 4. We agree. The term “wireless mobile phone” is only used in dependent claim 19 (not in independent claim 12, as Patent Owner alleges), and the principal reference relied on by Petitioner (Willgert) explicitly discloses the use of a mobile telephone. Ex. 1001, 12:2; Ex. 1004 ¶¶ 30–32. For these reasons, and because our analysis of the issues set forth below is not dependent on Patent Owner’s proposed construction, it is unnecessary to adopt Patent Owner’s construction or otherwise construe the term “wireless mobile phone.”” slip op. at 12
- Claim Construction › Intrinsic evidence (Phillips canons) › Specification disavowal / 'present invention' languageTerm construed petitioner constructionDecided for petitioner
“to an emulated radio frequency data input method” (Ex. 1001, 1:20–21), and the other references to emulation, are consistent with a conclusion that the claims encompass the “functional emulation” option as described above. However, there is no basis for adding the negative limitation proposed by Patent Owner (“without the use of a physical RFID transponder”). Omega Engineering, 334 F.3d at 1333 (rejecting a construction because “neither the plain text of the claims, the specification, nor the file wrapper justifies the imposition of this negative limitation”). See also BillJCo, LLC v. Apple Inc., No. 2023-2189, 2023-2190, 2025 WL 1417957, at *1 (Fed. Cir. May 16, 2025): Our court has “identified claim constructions that exclude a particular element as including a ‘negative limitation’ and held that such exclusions must find support either in ‘the words of the claim’ or through an ‘express disclaimer or independent lexicography in the written description that would justify adding that negative limitation.’” Ethicon LLC v. Intuitive Surgical, Inc., 847 F. App’x 901, 907 (Fed. Cir. 2021). Patent Owner’s argument that the claim language, “[a] transceiver . . . configured to output . . . RFID transponder [signals or data],” only makes sense “if the transceiver is not itself an RFID transponder” (Sur-Reply 10) is not persuasive. Examination of the complete version of the passage that Patent Owner only paraphrases — “[a] transceiver configured to output voice call signals in the first state and to output RFID transponder signals in the second state” — shows that the transceiver is capable of both voice call and RFID functions, and thus there is no inconsistency in allowing the RFID function to be performed by RFID transponder circuitry incorporated into the transceiver.” slip op. at 24
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“Petitioner argues that this combination would have been motivated by the fact that Willgert teaches that integrating its communications unit into a mobile telephone designed for Bluetooth communication was a “highly user-friendly application,” and that it was well known practice to use a Bluetooth headset wirelessly communicating with the phone to enable hands-free phone calls, as specifically taught by Mooney. Pet. 14–17 (citing Ex. 1004 ¶¶ 8, 30–32; Ex. 1005, Fig. 3, ¶¶ 7, 39, 46–48; Ex. 1021; Ex. 1003 ¶¶ 72–76). Petitioner further argues that Bluetooth headsets were widely available, that incorporating the headset involved known methods yielding predictable results, and that one of ordinary skill would have reasonably expected to succeed in combining the teachings of Willgert and Mooney. Id. at 17–19 (citing Ex. 1004 ¶ 10; Ex. 1005, ¶ 8; Ex. 1017, 1, 3; Ex. 1021, 2; Ex. 1003 ¶¶ 77–79). Patent Owner does not specifically address the issue of motivation to combine Willgert and Mooney. See generally PO Resp. We find, based on the record, that Petitioner has proved by a preponderance of the evidence that a person of ordinary skill in the art would have been motivated to combine Willgert and Mooney as proffered by Petitioner with a reasonable expectation of success.” slip op. at 31
Patent outcomesUS 8,381,974 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 8,381,974 - PTAB · Jan 14, 2026 · IPR2025-01191 · APJ Kara L Szpondowski · IPR · Institution
The Board instituted IPR on claims 1–24 and all asserted grounds because the petition showed a reasonable likelihood of prevailing on at least one claim.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Institution of an inter partes review is authorized when “the information presented in the petition . . . and any 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.” 35 U.S.C. § 314(a). Based on the current record, and for the reasons explained below, we determine that Petitioner has established a reasonable likelihood that it would prevail with respect to at least one challenged claim, and we institute an inter partes review.” slip op. at 2
- PTAB / AIA Trials › Discretionary denial › §325(d) same art / argumentsNot reached
“IV. PATENT OWNER’S 35 U.S.C. § 325(D) ARGUMENTS Patent Owner presents arguments directed to discretionary considerations under 35 U.S.C. § 325(d) and requests the Petition be denied based on these arguments. Prelim. Resp. 2–16. However, Patent Owner’s § 325(d) arguments are untimely under the “Interim Director Discretionary Process,”6 and, as such, will not be considered by the Board. See Section I.C. (“The . . . patent owner should not present discretionary considerations in the . . . Patent Owner Preliminary Response (POPR)”); Section I.E. (“[A] Board panel will issue a decision on institution addressing the merits and other non-discretionary considerations.”). 5 Available at https://www.uspto.gov/patents/ptab/trial-practice-guide#step1 6 https://www.uspto.gov/patents/ptab/interim-director-discretionary-process.” slip op. at 38
- Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication establishedDecided for petitioner
“Petitioner bears the burden of establishing that Wang is a printed publication. Medtronic, 891 F.3d at 1380. The determination of whether a document is a “printed publication” “involves a case-by-case inquiry into the facts and circumstances surrounding the reference's disclosure to members of the public.” In re Klopfenstein, 380 F.3d 1345, 1350 (Fed. Cir. 2004). “[A]t the institution stage, the petition must identify, with particularity, evidence sufficient to establish a reasonable likelihood that the reference was publicly accessible before the critical date of the challenged patent and therefore that there is a reasonable likelihood that it qualifies as a printed publication.” Hulu, IPR2018-01039, Paper 29 at 13.” slip op. at 19
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Instituted
“A claim is unpatentable as anticipated under 35 U.S.C. § 102 “if each and every limitation is found either expressly or inherently in a single prior art reference.” WhitServe, LLC v. Computer Packages, Inc., 694 F.3d 10, 21 (Fed. Cir. 2012) (quoting Celeritas Techs., Ltd. v. Rockwell Int’l Corp., 150 F.3d 1354, 1361 (Fed. Cir. 1998)). An anticipatory reference must also “disclose those elements ‘arranged as in the claim.’” Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359, 1369 (Fed. Cir. 2008) (quoting Connell v. Sears, Roebuck & Co., 722 F.2d 1542, 1548 (Fed. Cir. 1983)).” slip op. at 11
Claim construction§ 102 anticipation§ 103 obviousnessDiscretionary denialcites KSR · GrahamPatents in suitUS 10,822,165 - Tanklogix, LLC v. SiteproInstitution deniedPTAB · Oct 10, 2025 · IPR2025-00650 · APJ Sheila F Mcshane · IPR · Institution
The Board denied institution because Petitioner did not show a reasonable likelihood that claims 18–32 and 34 were unpatentable over Kahn or Kahn and Gutierrez.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“information presented in the petition . . . and any 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.” 35 U.S.C. § 314(a) (2024). Upon consideration of the Petition, the Preliminary Response, and the evidence of record, we determine that Petitioner has not established a reasonable likelihood of prevailing with respect to the unpatentability of at least one claim of the ’871 patent. Accordingly, for the reasons that follow, we decline to institute an inter partes review of claims 18–32 and 34 of the ’871 patent.” slip op. at 2
- Skill levelSkill level patent owner adoptedDecided for patent owner
“The respective proposed levels of qualifications for a person of ordinary skill in the art are similar, with Patent Owner proposing two years of experience compared to Petitioner proposing significant experience with remotely controlling fluid-handling devices, like SCADA systems. Patent Owner also proposes more extensive experience in lieu of educational experience. While we find Petitioner’s proposed qualifications to be acceptable, we adopt Patent Owner’s proposed qualifications for the purposes of this Decision because they offer a wider range of qualifications that nonetheless comport with the level of skill necessary to understand and implement the teachings of the ’871 patent and the asserted prior art. Our analysis and findings herein, however, do not turn on any differences in the qualifications adopted.” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“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 10
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable
“actuators and the remote control of fluid handling devices, including the receipt with the user-interface module of “a user command to actuate an actuator via a presented control interface” (limitation [18.7]) and “account authorized to send commands to remotely control fluid handling devices” (limitation [18.11]). We agree with Patent Owner that the Petition fails to demonstrate that Kahn discloses or teaches these limitations because the evidence does not provide support that there is remote control of fluid handling devices or the use of a user command on a control interface to send a command to a fluid handling device, for instance. Kahn is directed to providing access to fluid sensing data and analyzing and providing visual information on that data, but we do not discern that it teaches or discloses the capability to remotely control fluid handling devices. See, e.g., Ex. 1005, code (54), 1:27–36, 2:50–3:2. More specifically, the Kahn disclosures that Petitioner repeatedly relies upon for allegedly teaching this control are deficient. See Ex. 1005, 10:62–67, 14:35– 15:2, 15:62–16:32; see also Pet. 12–14, 16–18. Kahn discloses that “the communication unit 112B can include on-site alerts such as optical (indicator lights), audible alerts (e.g., alarm sounds), tactile (e.g., vibration of the unit) or can be interfaced to an appropriate control valve for simply shutting off the supply of fluid upon the detection of emergency events, for instance.” Ex. 1005, 10:62–67. Communication unit 112B is part of the local “sensor unit,” wherein the detection conditions determined by the sensor are communicated to remote devices by communication unit 112B. See id. at 3:31–33, 5:62–6:2, 6:27–35, 7:33–37, 13:7–12, Figs. 1A–1C. Kahn discloses that the sensor units, which include communication units 112B, can be located near shut-off valves and can communicate with distant locations. See id. at 11:1–13. There are no disclosures, however, in the above passages that there is remote control of fluid handling devices, that there is a user command on a control interface that actuates an actuator, or that there is a command sent to the facility actuators via a network connection, as required in limitations [18.5]–[18.7] and [18.9]–[18.12], respectively. Rather, the disclosure indicates that the communication unit 112B includes on-site alerts and that the local (non-remote) communication unit 112B can be interfaced with the control valve.” slip op. at 18
Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,488,871 - Interactive Communications International, Inc. v. Blackhawk Network Inc.All claims unpatentablePTAB · Jul 14, 2025 · IPR2024-00465 · APJ Bart A Gerstenblith · IPR · Final written decision
Claims 1–24 are unpatentable: claims 1–10 and 12–24 as obvious over Szrek and Llach, and claim 11 as obvious over Szrek, Llach, and Gilmore.
RulingsFinal written decision- Skill levelSkill level board ownDecided for petitioner
“B. Level of Ordinary Skill in the Art Petitioner proposes that the level of ordinary skill in the art is an artisan with a working knowledge of POS activation systems and lottery systems that was gained through a mixture of training and work experience in the relevant field such as (i) having a Bachelor’s degree in computer science, computer communications, electrical engineering, or equivalent degree, coupled with at least three years of work experience; (ii) having a Master’s degree in computer science, computer communications, or electrical engineering, but having less work experience; or (iii) having no formal degree, but having experience in the relevant field of at least six years of work experience. Pet. 2–3 (citing Ex. 1003 ¶¶ 13–14).9 Patent Owner states that, “[f]or the purpose of this proceeding, Patent Owner adopts the Petition’s proposed definition of the level of ordinary skill in the art.” PO Resp. 19 (citing Pet. 2–3). We find that the parties’ agreed-upon level of ordinary skill in the art is consistent with the level of ordinary skill in the art reflected by the ’451 patent and the prior art of record. See Inst. Dec. 14; see Okajima v. 9 Petitioner proposes the same level of ordinary skill in the art that the Board adopted in PGR2020-00084 (Pet. 2–3 (citing Ex. 1008, 11)), and IPR2023- 01235 (see IPR2023-01235, Paper 34 at 12–13). 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). Therefore, we adopt the parties’ agreed-upon level of ordinary skill in the art, as articulated above, in our consideration of the issues presently before us.” slip op. at 13
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“We need not construe “transaction processor” expressly because its meaning is not in dispute and its construction is not necessary to resolve the controversy before us.” slip op. at 16
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“On balance, we find that even with the alleged disadvantages identified by Patent Owner, one of ordinary skill in the art would have been motivated to modify Szrek with Llach’s third-party transaction processor because the advantage of having a “centralized intermediary” allows Szrek’s system to support different game providers, such as different lottery companies, which would reduce some implementation costs and allow the system to be more easily and cheaply extended. Pet. 47 (citing Ex. 1003 ¶ 181); see Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006) (“a given course of action often has simultaneous advantages and disadvantages, and this does not necessarily obviate motivation to combine”) (citing Winner Int’l Royalty Corp. v. Wang, 202 F.3d 1340, 1349 n.8 (Fed. Cir. 2000)); see also Intel Corp. v. Qualcomm Inc., 21 F.4th 784, 795 (Fed. Cir. 2021) (stating the same). We acknowledge that the combination comes with some disadvantages, including “add[ed] delay, reduce[d] efficiency, and . . . implementation complexities by converting a simple, direct communication exchange into an exchange that traverses multiple systems.” PO Resp. 52 (citing Ex. 2052 ¶ 163). But, “[t]he fact that the motivating benefit comes at the expense of another benefit, however, should not nullify its use as a basis to modify the disclosure of one reference with the teachings of another. Instead, the benefits, both lost and gained, should be weighed against one another.” Winner, 202 F.3d at 1349 n.8. Here, Szrek expressly teaches indirect communication as a possible implementation of its system and Petitioner’s combination—employing Llach’s third-party transaction processor as part of the indirect communication channel—offers the attractive benefit of allowing Szrek’s system to support different game providers, which would reduce some implementation costs even if it might increase other costs, e.g., by having to program certain components (e.g., the cash registers) differently. Specifically, we find that the ability to expand Szrek’s system to support different game providers provides advantages that outweigh the disadvantages discussed above in the circumstance where one desires a more robust and comprehensive system. See Pet. Reply 23 (noting three advantages of the combination— (1) “allow[ing] Szrek’s system to use ‘a centralized system for activating lottery tickets from different retailers and different locations,’” (2) “allow[ing] support for different game providers, such as different lottery companies,” “reduc[ing] implementation costs,” and (3) “allow[ing] Szrek’s system to ‘communicate with individual card” slip op. at 37
- Obviousness (§103) › Motivation to combine / reasonable expectation of success › HindsightMotivation foundDecided for petitioner
“On balance, we find that even with the alleged disadvantages identified by Patent Owner, one of ordinary skill in the art would have been motivated to modify Szrek with Llach’s third-party transaction processor because the advantage of having a “centralized intermediary” allows Szrek’s system to support different game providers, such as different lottery companies, which would reduce some implementation costs and allow the system to be more easily and cheaply extended. Pet. 47 (citing Ex. 1003 ¶ 181); see Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006) (“a given course of action often has simultaneous advantages and disadvantages, and this does not necessarily obviate motivation to combine”) (citing Winner Int’l Royalty Corp. v. Wang, 202 F.3d 1340, 1349 n.8 (Fed. Cir. 2000)); see also Intel Corp. v. Qualcomm Inc., 21 F.4th 784, 795 (Fed. Cir. 2021) (stating the same). We acknowledge that the combination comes with some disadvantages, including “add[ed] delay, reduce[d] efficiency, and . . . implementation complexities by converting a simple, direct communication exchange into an exchange that traverses multiple systems.” PO Resp. 52 (citing Ex. 2052 ¶ 163). But, “[t]he fact that the motivating benefit comes at the expense of another benefit, however, should not nullify its use as a basis to modify the disclosure of one reference with the teachings of another. Instead, the benefits, both lost and gained, should be weighed against one another.” Winner, 202 F.3d at 1349 n.8. Here, Szrek expressly teaches indirect communication as a possible implementation of its system and Petitioner’s combination—employing Llach’s third-party transaction processor as part of the indirect communication channel—offers the attractive benefit of allowing Szrek’s system to support different game providers, which would reduce some implementation costs even if it might increase other costs, e.g., by having to program certain components (e.g., the cash registers) differently. Specifically, we find that the ability to expand Szrek’s system to support different game providers provides advantages that outweigh the disadvantages discussed above in the circumstance where one desires a more robust and comprehensive system. See Pet. Reply 23 (noting three advantages of the combination— (1) “allow[ing] Szrek’s system to use ‘a centralized system for activating lottery tickets from different retailers and different locations,’” (2) “allow[ing] support for different game providers, such as different lottery companies,” “reduc[ing] implementation costs,” and (3) “allow[ing] Szrek’s system to ‘communicate with individual card” slip op. at 37
Patent outcomesUS 11,488,451 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,488,451 - Inergy Technology, Inc. v. Force Mos Technology Co., Ltd.No claims unpatentablePTAB · May 16, 2025 · IPR2024-00093 · APJ Grace Karaffa Obermann · IPR · Final written decision
Claims 1–9 were not proven unpatentable because the asserted references did not establish the claimed epitaxial layer or the required coverage of the trench sidewalls.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner defines a person of ordinary skill in the art as having “a Master’s degree in electrical engineering, and at least two years of relevant work experience in the field of integrated circuit design and manufacturing.” Pet. 13 (citing Ex. 1003 ¶¶ 32–37, 57). Patent Owner does not dispute Petitioner’s definition. PO Resp. 6. We adopt Petitioner’s proposed definition of the level of ordinary skill in the art because it is supported by unopposed declaration testimony and appears to be consistent with the disclosures of the ’634 patent and the asserted prior art references. See Ex. 1001, 1:6–2:33 (describing the invention and related art in terms of integrated circuit design and fabrication); see also Ex. 1006 ¶¶ 1–6 (Hirler); Ex. 1008 ¶¶ 1–37 (Kobayashi); Ex. 1009 ¶¶ 2–29 (Shiraishi). Neither party, moreover, indicates the overall result would change based on a different definition.” slip op. at 7
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“Petitioner argues that “the sidewalls of said trenches in said base layer are covered” should be construed to mean that “the entire sidewalls of” those trenches are covered. Pet. 18–19. We refer to this as “the sidewall limitation.” Petitioner shows persuasively that the disclosure and file history of the ’634 patent support its position on the sidewall limitation. Id. Patent Owner, for its part, observes that, after the filing of the Petition. two District Courts adopted the construction proposed by Petitioner.” PO Resp. 21 (citing Ex. 2010, 6–9; Ex. 2011, 23). Patent Owner also agrees to apply Petitioner’s construction for purposes of this proceeding. Id. We agree with Patent Owner that an express construction of the sidewall limitation is necessary to this Decision, id., and adopt Petitioner’s undisputed definition because it is supported by the record. No other claim term requires express construction for purposes of this Decision.” slip op. at 8
- BurdenNot shown unpatentable
“On this record, Petitioner fails to demonstrate that any claim is unpatentable under any ground asserted in the Petition. IV. CONCLUSION For the above reasons, we determine that Petitioner fails to establish by a preponderance of the evidence that claims 1–9 of the ’634 patent are unpatentable.” slip op. at 34
- Expert testimonyPetitioner expert discountedPatent owner expert creditedDecided for patent owner
“Alternatively, even if we set aside that timing issue, Dr. Liu’s bare opinion, advanced for the first time during cross-examination, that an epitaxial layer is “obvious” from Hirler’s disclosure is inadequate to support the challenges. Id. at 24–25. We accord little weight to Dr. Liu’s opinion because it is conclusory. See Xerox Corp. v. Bytemark, Inc., IPR2022-00624, Paper 9 at 15 (PTAB Aug. 24, 2022) (precedential). In any event, Petitioner does not meet, on this record, the “high standard” required to establish an inherent disclosure of an epitaxial layer in Hirler. PO Resp. 24.6 Dr. Liu opined for the first time during cross-examination “that it would have been impossible to create Hirler’s more lightly doped n- drift zone layer on top of its more heavily doped n+ substrate layer other than via epitaxy.” Id. at 25 (citing Ex. 2014, 164:16– 165:20). But Patent Owner effectively refutes that proposition with evidence that such a layer “could be created by counter-doping,” even if, as Dr. Liu contends, counter-doping may have been less ideal due to “disadvantageous mobility.” Id. (citing Ex. 2012 ¶ 133; Ex. 2014, 166:15–167:8).” slip op. at 11
Patent outcomesUS 7,629,634 not shown unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 7,629,634
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.