- Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.All claims unpatentablePTAB · Jun 1, 2026 · IPR2025-00117 · APJ Michael T Cygan · IPR · Final written decision
Claims 1–19 are unpatentable: claims 1–9, 11–16, 18, and 19 as obvious over Kim; claims 10 and 17 as obvious over Kim and Fang, Park, and Park and Fang.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“at the critical time “would have had a bachelor of science degree in electrical engineering or a similar discipline, along with 2-3 years of professional experience working with (e.g., researching, designing, or teaching) monolithic 3D structures and NAND flash memory devices, or an equivalent level of skill, knowledge, and experience (e.g., an advanced degree may replace some of the professional experience).” Pet. 27 (citing Ex. 1003 ¶ 42). Petitioner further asserts that a POSITA “would have been aware of and generally knowledgeable about 3D NAND’s structure, its component parts, how it operates, and how it is controlled.” Id. Patent Owner does not dispute Petitioner’s definition. PO Resp. 7. We adopt Petitioner’s proposed 4 Neither party presents evidence or arguments regarding objective evidence of non-obviousness. Pet. 103; PO Resp. the ’711 patent and the prior art of record.” slip op. at 5
- Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed petitioner constructionDecided for petitioner
“Based on the record before us, we agree with Petitioner that “on a surface” should be interpreted in line with the definition of “on” set forth in the ’711 patent. Ex. 1001, 4:1–6. We particularly note that the ’711 patent states that “‘on’ . . . should be interpreted in the broadest manner” and that “on” is not limited to “directly on.” Id. Instead, the ’711 patent states that “‘on’ also includes the meaning of ‘on’ something with an intermediate feature or layer therebetween.” Id. Patent Owner agrees that this definition controls the “standalone ‘on’” term such that A may be on B even if there is an intervening layer between them. Tr. 55:8–11 (“The standalone ‘on,’ we agree in the context of the patent, you can have intervening layers. I think the patent is clear about that.”). Claim 14 recites that the etch-stop layer is “on” something; i.e., “on a side surface and a top surface of each step.” Ex. 1001, 16:20–22. Patent Owner agrees that a surface is a “something.” Tr. 56:5–8 (“surface obviously is a something”). Substituting the “a “‘on’ something with an intermediate feature or layer therebetween” results in claim 14 reading as, “on a surface with an intermediate feature or layer therebetween.” Unlike “directly on,” which specifies the relation between two things, “a surface” may merely indicate the thing that something is “on,” particularly when “on” is “interpreted in the broadest manner” as expressly required by the ’711 patent.” slip op. at 7
- Expert testimonyPatent owner expert discountedDecided for petitioner
“Although Dr. Campbell testified in his deposition in response to Petitioner’s counsel that “on the surface” requires direct contact with the surface, his interpretation was based on “embodiments of” the patent rather than a general understanding of a person skilled in the art confronted with that term. Ex. 1027, 122:6–25, 124:6–23 (“I’m not sure if there are other sources for that, but it was on the ’711, so I’ve taken it there.”). Dr. Campbell, upon questioning from Patent Owner’s counsel, later stated that “an expert in semiconductor fabrication” would understand “on the surface” to mean “contact between one layer and another . . . with nothing in between.” Id. at 146:25–147:6. However, Dr. Campbell did not explain why such an interpretation is particular to the semiconductor fabrication art, or provide other explanation or support for this statement, which is in tension with the definition of “on” in the ’711 patent. Accordingly, we significantly discount the weight accorded to that statement. Phillips, 415 F.3d at 1318 (stating, “conclusory, unsupported assertions by experts as to the definition of a claim term are not useful to a court. Similarly, a court should discount any expert testimony ‘that is clearly at odds with the claim construction mandated by the claims themselves, the written description, and patent.’”). On balance, Dr. Campbell’s testimony is best understood as a description of certain Figures of the ’711 patent rather than a representation of an ordinarily skilled person’s understanding of the term “on the surface.” See Ex. 2009 ¶ 47 (describing Figs. 1, 3, and 4 as depicting layers in contact with the underlying layer or substrate). For example, Dr. Campbell describes Figure 9A as having a barrier layer “on and directly contacting the top and side surfaces of each step.” Id. ¶ 28 (emphasis added) (citing inter alia Ex. 1001, 7:6–67). Dr. Campbell does not explain why, beyond the fact that many Figures show layers as adjacent and in contact, a person of ordinary skill in the relevant art would understand those Figures to limit the claim language rather than illustrating particular embodiments that fall within a broader scope of claims 14 and 15. See Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367, 1371 (Fed. Cir. 2014) (“While we read claims in view of the specification, of which they are a part, we do not read limitations from the embodiments in the specifications into the claims.”).” slip op. at 9
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“We agree with Petitioner that Kim’s first and second section are described as compatible, not mutually exclusive, embodiments. Kim’s second section builds further layers upon the structure of its first section, and states: In these embodiments, the same elements as in the embodiments previously described with reference to FIGS. 5A through 14A and FIGS. 5B through 14B will be denoted by the same reference numbers therein, and for concise description, overlapping description of elements previously described with reference to FIGS. 5A through 14A and FIGS. 5B through 14B may be omitted. Ex. 1005 ¶ 184 (emphasis added). Patent Owner argues that only the embodiments in Figures 17A–22B describe an etch-stop layer and a barrier layer (as claimed), and that the language cited for a gate-stack-on-top configuration (e.g., Ex. 1005 ¶¶ 90, 91, and 240) is “conspicuously absent from the description of Figures 17A–22B.” PO Resp. 20 (citing Ex. 2009 ¶ 36). However, Figures 17A–22B do not further address the underlying staircase structure that was detailed in the descriptions of the Figures 4 through 15 embodiments. While Figures 17A–22B show a gate-stack-on-bottom configuration, this merely continues the gate-stack-on-bottom illustrations that were used in all of the previous Figures, even for those in which it is undisputed that a gate-stack-on-top configuration is a described alternative. The Figures exemplify rather than limit the description of the gate-stack-on-bottom view in Figures 4–15 and do not exclude the gate-stack on bottom description of the embodiments exemplified by those figures.” slip op. at 17
Patent outcomesUS 10,672,711 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,672,711 - Avanos Medical, Inc. v. Stratus Medical, LLCAll claims unpatentablePTAB · Mar 10, 2026 · IPR2024-01209 · APJ Susan L C Mitchell · IPR · Final written decision
Claims 1–27 are unpatentable as obvious over the asserted combinations, principally Racz, Fitz, and Lee; both parties’ motions to exclude are dismissed as moot.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“PO Resp. 30 (citing Ex. 2006 ¶ 58). Patent Owner’s proposal is too narrow in two respects. First, it mandates certain education and experience in RF neurotomy specifically. This is too narrow as the description of the scope of the invention set forth in the ’782 patent as described above is not limited to RF neurotomy. Second, it requires the POSA to be both a physician who performs thermal ablation (RF neurotomy specifically) and an engineer with training and experience “in the design and development of devices and methods” for performing the same. Id. This is too narrow because it excludes physicians and other advanced degree holders who research and design devices and methods for performing thermal ablation but do not actually operate on patients. We adopt the Petitioner’s definition of a POSA, quoted above, as it is reflective of the level of skill in the art when viewed in light of the disclosure of the ’782 patent. Supra (quoting Pet. 11).” slip op. at 16
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“With respect to the challenged claims, Petitioner contends that no claim term requires express construction. Pet. 12 (citing Ex. 1031 ¶106 (Dr. Robert D. Tucker’s11 testimony that “the terms in the Challenged Claims would be understood by a POSA to have their plain and ordinary meaning and do not require a special construction or definition”)). In instituting the IPR, we found no need to provide an express construction of any claim term. Inst. Dec. 12. We likewise find no need to do so now, as neither party has proposed a construction for any claim term and none of the parties’ arguments turns on a disputed meaning of any claim language.” slip op. at 11
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“(Fed. Cir. 1985)). “Whether a reference in the prior art is ‘analogous’ is a fact question.” Clay, 966 F.2d at 658. “Two criteria have evolved for determining whether prior art is analogous: (1) whether the art is from the same field of endeavor, regardless of the problem addressed, and (2) if the reference is not within the field of the inventor’s endeavor, whether the reference still is reasonably pertinent to the particular problem with which the inventor is involved.” Id. at 658–59. Patent Owner argues that Lee is not analogous art under the first criterion because “Lee does not relate to neurotomy at all.” PO Resp. 34. However, as discussed above, the field of the invention is not limited to neurotomy. The field of the invention is thermal ablation generally, which encompasses RF neurotomy, but which is not limited to RF neurotomy. Accordingly, we are not persuaded by Patent Owner’s argument. To the contrary, we are persuaded by Petitioner’s argument that Lee is analogous art, under at least the first Clay criterion, because it “discloses various techniques for deploying electrodes from the tip of an RF ablation device.” Pet. 18.” slip op. at 24
- Expert testimonyPetitioner expert creditedDecided for petitioner
“Dr. Tucker’s testimony is not a bald conclusion. His conclusion as to a reasonable expectation of success is set forth in paragraph 148 of his declaration. Ex. 1031 ¶148. It is supported extensively with testimony regarding what the prior art teaches (see id. ¶¶110–117 (Racz), ¶¶118–123 (Fitz), ¶¶124–131 (Lee)) and why and how a POSA would have combined the prior art teachings (see id. ¶¶132–147). Dr. Tucker’s testimony clearly is entitled to weight. Since 1983, he has “been a Professor at the University of Iowa where [he] direct[s] an active research program in radiofrequency electrosurgical procedures and instrumentation.” Ex. 1031 ¶3. He has a Ph.D. in biophysics, and he is also a medical doctor (albeit he is not Board certified as pointed out by Patent Owner19). Id. ¶2. He also has additional training and experience that is relevant, but which is not necessary, but further establishes that he is well qualified to offer the opinions set forth in his declaration. Id. ¶¶2–11. Patent Owner argues that Dr. Tucker is not qualified to testify here because “he is not Board certified” and he is “not a pain-specialist physician and has never performed a neurotomy.” PO Resp. 30. Dr. Tucker explained, however, that he is not Board certified nor does he operate on 19 See PO Resp. 30 (citing Ex. 2020, 10:19–12:20). patients because his work focuses on the development of instrumentation, not the use of it, explaining on cross-examination:” slip op. at 39
Patent outcomesUS 10,966,782 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,966,782 - Avanos Medical, Inc. v. Stratus Medical, LLCAll claims unpatentablePTAB · Mar 6, 2026 · IPR2024-01211 · APJ Michael J Fitzpatrick · IPR · Final written decision
Claims 18–47 and 53–74 are unpatentable as obvious over the asserted combinations of Racz, Fitz, Lee, and the additional references in Grounds 2–8.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“In sum, the field of the invention is thermal ablation. It encompasses RF neurotomy, but it is not limited to RF neurotomy. With that settled, we turn now to the person of ordinary in the field/art (POSITA or POSA).” slip op. at 17
- Expert testimonyPetitioner expert creditedDecided for petitioner
“Dr. Tucker’s testimony is not a bald conclusion. His conclusion as to a reasonable expectation of success is set forth in paragraph 162 of his declaration. Ex. 1033 ¶162. It is supported extensively with testimony regarding what the prior art teaches (see id. ¶¶124–131 (Racz), ¶¶132–137 (Fitz), ¶¶138–145 (Lee)) and why and how a POSA would have combined the prior art teachings (see id. ¶¶146–161). Dr. Tucker’s testimony clearly is entitled to weight. Since 1983, he” slip op. at 39
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“35. “Although § 103 does not, by its terms, define the ‘art to which [the] subject matter [sought to be patented] pertains,’ this determination is frequently couched in terms of whether the art is analogous or not, i.e., whether the art is ‘too remote to be treated as prior art.’” In re Clay, 966 F.2d 656, 658 (Fed. Cir. 1992) (quoting In re Sovish, 769 F.2d 738, 741 (Fed. Cir. 1985)). “Whether a reference in the prior art is ‘analogous’ is a fact question.” Id. at 658. “Two criteria have evolved for determining whether prior art is analogous: (1) whether the art is from the same field of endeavor, regardless of the problem addressed, and (2) if the reference is not within the field of the inventor’s endeavor, whether the reference still is reasonably pertinent to the particular problem with which the inventor is involved.” Id. at 658–59. Patent Owner argues that Lee is not analogous art under the first criterion because “Lee does not relate to neurotomy at all.” PO Resp. 33. However, as discussed above, the field of the invention is not limited to neurotomy. The field of the invention is thermal ablation generally, which encompasses RF neurotomy, but which is not limited to RF neurotomy. Accordingly, we are not persuaded by Patent Owner’s argument. To the contrary, we are persuaded by Petitioner’s argument that Lee is analogous art, under at least the first Clay criterion, because it “discloses various techniques for deploying electrodes from the tip of an RF ablation device.” Pet. 17.” slip op. at 25
- BurdenDecided for petitioner
“Patent Owner does not identify any legal requirement for petitions to illustrate proposed combinations of prior art features. Indeed, the very statute identified by Patent Owner as “requiring petitions to set forth challenge grounds ‘with particularity’” (see PO Resp. 36) calls for the requisite particularity to be “in writing,” not by illustration. See 35 U.S.C. § 312(a)(3) (“A petition filed under section 311 may be considered only if . . . (3) the petition identifies, in writing and with particularity . . . the grounds on which the challenge to each claim is based.”). Simply put, there is no legal requirement to provide multiple illustrations of a proposed combination of prior art features (as Patent Owner implies), let alone a single illustration (as Petitioner has done).” slip op. at 28
Patent outcomesUS 10,736,688 unpatentable§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,736,688 - Avanos Medical, Inc. v. Stratus Medical, LLCAll claims unpatentablePTAB · Mar 6, 2026 · IPR2024-01210 · APJ Michael J Fitzpatrick · IPR · Final written decision
Claims 1–17 and 48–52 are unpatentable as obvious over the asserted combinations of prior art, principally Racz, Fitz, and Lee.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“In sum, the field of the invention is thermal ablation. It encompasses RF neurotomy, but it is not limited to RF neurotomy. With that settled, we turn now to the person of ordinary in the field/art (POSITA or POSA).” slip op. at 16
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“F.2d 656, 658 (Fed. Cir. 1992) (quoting In re Sovish, 769 F.2d 738, 741 (Fed. Cir. 1985)). “Whether a reference in the prior art is ‘analogous’ is a fact question.” Id. at 658. “Two criteria have evolved for determining whether prior art is analogous: (1) whether the art is from the same field of endeavor, regardless of the problem addressed, and (2) if the reference is not within the field of the inventor’s endeavor, whether the reference still is reasonably pertinent to the particular problem with which the inventor is involved.” Id. at 658–59.” slip op. at 24
- BurdenDecided for petitioner
“illustrate proposed combinations of prior art features. Indeed, the very statute identified by Patent Owner as “requiring petitions to set forth challenge grounds ‘with particularity’” (see PO Resp. 36) calls for the requisite particularity to be “in writing,” not by illustration. See 35 U.S.C. § 312(a)(3) (“A petition filed under section 311 may be considered only if . . . (3) the petition identifies, in writing and with particularity . . . the grounds on which the challenge to each claim is based.”). Simply put, there is no legal requirement to provide multiple illustrations of a proposed combination of prior art features (as Patent Owner implies), let alone a single illustration (as Petitioner has done).” slip op. at 26
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“a POSA would have had an apparent reason to make Racz’s modified device. Pet. 22–27. We need not address these additional arguments and evidentiary citations, however, as Petitioner has demonstrated by a preponderance of the evidence that implementing deployable filaments on the distal tip of an RF ablation device was a known technique for expanding and controlling the ablation volume. Thus, so long as there would have been a reasonable expectation of success in making Racz’s modified device (addressed infra), the combination would have been obvious. See Intel Corp., 61 F.4th at 1380 (“[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 unless its actual application is beyond his or her skill.”); Medichem, 437 F.3d at 1165 (“[A]n obviousness determination requires not only the existence of a motivation to combine elements from different prior art references, but also that a skilled artisan would have perceived a reasonable expectation of success in making the invention via that combination.”).” slip op. at 31
Patent outcomesUS 10,736,688 unpatentable§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,736,688 - Avanos Medical, Inc. v. Stratus Medical, LLCAll claims unpatentablePTAB · Mar 5, 2026 · IPR2024-01212 · APJ Arthur M Peslak · IPR · Final written decision
Claims 1–29 are unpatentable because Petitioner showed by a preponderance of the evidence that the asserted prior-art combinations rendered them obvious under §103.
RulingsFinal written decision- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“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 unless its actual application is beyond his or her skill.” KSR, 550 U.S. at 417. In this case, we must determine whether one of ordinary skill in the art would recognize that applying the teachings of Fitz and Lee of deploying multiple filaments to increase and control the ablation volume to Racz’s distal tip would improve Racz’s device in the same way. For us to resolve this question in Petitioner’s favor, Petitioner must provide “some articulated reasoning with some rational underpinning to support the legal conclusion of obviousness.” Id. at 418 (citing In re Kahn, 441 F.3d at 988). However, bodily incorporation, i.e., “an actual physical substitution of” Lee’s filaments into Racz is not required. See In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012) (“It is well-established that a determination of obviousness based on teachings from multiple references does not require an actual, physical substitution of elements.”); In re Nievelt, 482 F.2d 965, 968 (CCPA 1973) (“Combining the teachings of references does not involve an ability to combine their specific structures.”).” slip op. at 30
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“11. Balancing the Graham Factors After weighing all the evidence submitted by the parties in light of the Graham factors, we determine Petitioner has demonstrated by a preponderance of the evidence that the claims 1, 3–10, 18–26, 28, and 29 would have been obvious over Racz, Fitz, and Lee. As discussed above, Petitioner’s evidence establishes that the combination of Racz, Fitz, and Lee teaches every limitation of claims 1, 3–10, 18–26, 28, and 29 and that an ordinarily skilled artisan would have been motivated to combine Racz, Fitz, and Lee with a reasonable expectation of success. Further, as discussed above, Patent Owner’s evidence of secondary considerations is entitled to little, if any, weight because Patent Owner fails to establish nexus. Consequently, after considering all the evidence in the record both for and against patentability, we determine that Petitioner has shown by a preponderance of the evidence that claims 1, 3–10, 18–26, 28, and 29 would have been obvious over Racz, Fitz, and Lee. E. Ground B: Obviousness in view of Racz, Fitz, Lee and Young ’965 Petitioner contends that claims 1–10, 18–26, and 28–29 are also obvious over Racz, Fitz, Lee, and Young ’965. Pet. 62–67. Patent Owner argues that Young ’965 does not cure the alleged deficiencies in Ground 1, is directed to tumor ablation not neurotomy, would require a substantial redesign of Racz’s modified device, and there is no motivation to combine. PO Resp. 59–60. We start with a brief overview of Young ’965 and address the parties’” slip op. at 78
- ExcludeMotion to exclude, deniedDenied
“Accordingly, both Motions are dismissed as moot.” slip op. at 94
- Skill levelSkill level petitioner adoptedDecided for petitioner
“A. Level of Ordinary Skill in the Art In determining the level of skill in the art, we consider the type of” slip op. at 12
Patent outcomesUS 10,925,664 unpatentable§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,925,664 - Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.No claims unpatentablePTAB · Jan 5, 2026 · IPR2024-00911 · APJ Kimberly Mcgraw · IPR · Final written decision
Claim 10 was not shown unpatentable under § 103 over Toyama because the challenge did not remedy the deficiencies in its nonobvious base claim 8.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedOther
“Petitioner’s proposed definition appears to be consistent with the cited prior art and the disclosure of the ’806 patent, and we adopt it for purposes definition of a POSITA.” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“In our Decision on Institution, we noted that the parties disputed construction of “each local contact” found in dependent claim 10, and “dielectric structure” recited in independent claim 8. Inst. Dec. 8–9. We determine that no express construction of “each local contact” recited in claim 10, or any other claim term, is required to resolve the issues in dispute in this proceeding.” slip op. at 9
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable
“independent claim 8 would have been obvious for the reasons set forth in its petition in the 791-IPR. See id. at 1 (stating the present Petition maintains the same grounds set forth in IPR2024-00791). As explained in our Final Written Decision (Ex. 3001) in the 791-IPR issued concurrently, Petitioner did not show by a preponderance of the evidence that independent claim 8 would have been obvious over Toyama under any of Petitioner’s three alternative arguments. None of Petitioner’s arguments set forth in the present Petition, including the arguments directed to claim 10, remedy the deficiencies regarding its base claim 8. See Pet. 53–31, 98–101, 124–125; see also Reply. Accordingly, for the same reasons set forth in the Final Written Decision in the 791-IPR issued concurrently, Petitioner has not shown by a preponderance of the evidence that independent claim 8, and therefore dependent claim 10, would have been obvious over Toyama. See In re Fine, 837 F.2d 1071, 1076 (Fed. Cir. 1988) (“Dependent claims are nonobvious under section 103 if the independent claims from which they depend are nonobvious.”); Ex. 3001.” slip op. at 14
- Expert testimonyNot reached
“Petitioner relies on the Declaration of Jack C. Lee, Ph. D. (Ex. 1003) and the Reply Declaration of Jack C. Lee, Ph.D. (Ex. 1043) in support of its 2 The Leahy-Smith America Invents Act (“AIA”), Pub. L. No. 112–29, 125 Stat. 284 (2011), revised 35 U.S.C. §§ 102 and 103 effective March 16, 2013. Because the ’806 patent has an effective filing date after March 16, 2013 (Ex. 1001, codes (22), (63)), we refer to the AIA version of Sections 102 and 103. 3 Toyama, US Pub. No. 2017/0179026 A1, published June 22, 2017 (Ex. 1005). 4 Petitioner characterizes its alternative arguments of unpatentability of claim 10 as based on three “grounds.” See Pet. 15. Because each of Petitioner’s arguments are based on the same reference, albeit different embodiments, we characterize Petitioner’s challenges as three alternative arguments based on a single ground because each argument relies on the same reference. Ph.D. (Ex. 2005). Transcripts of the depositions of Dr. Lee (Exs. 2006, 2010) and of Dr. Yang (Ex. 1044) have also been submitted into the record.” slip op. at 7
Patent outcomesUS 10,937,806 not shown unpatentableClaim construction§ 103 obviousnesscites PhillipsPatents in suitUS 10,937,806 - Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.No claims unpatentablePTAB · Jan 5, 2026 · IPR2024-00791 · APJ Kimberly Mcgraw · IPR · Final written decision
Claims 8, 9, 11, and 12 were not shown unpatentable under §103 over Toyama because the asserted structures did not meet the construed TAC limitation and the proposed modifications lacked adequate motivation.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“(“POSITA”) would have had “a bachelor of science degree in electrical engineering or a similar discipline” with “2–3 years of professional experience working with (e.g., researching, designing, or teaching) NAND flash memory devices, or an equivalent level of skill, knowledge, and experience (e.g., an advanced degree may replace some of the professional experience).” Pet. 27 (citing Ex. 1003 ¶¶ 34–38). Petitioner further contends that a “POSITA would also have been aware of and generally knowledgeable about semiconductor manufacturing and 3D NAND’s structure, its component parts, how it operates, and how it is controlled.” Id. Patent Owner does not object to Petitioner’s proposed definition (PO Resp. 12), but Patent Owner’s declarant Dr. Yang provides a slightly different definition, stating a POSITA: would have had at least a bachelor’s degree in electrical engineering, materials science, or a similar discipline, along with at least 2 years of professional experience in semiconductor fabrication process integration for memory devices or an equivalent level of knowledge and experience. For example, an experience, or extensive experience may replace some of the educational requirements. Ex. 2004 ¶ 43. Petitioner’s proposed definition appears to be consistent with the cited prior art and the disclosure of the ’806 patent, and we adopt it for purposes of this Decision. We note that our Decision would be the same under either definition of a POSITA.” slip op. at 8
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for patent owner
“(TACs) extending vertically through the dielectric structure” recited in claim element [8.G] encompasses multiple TACs, each extending through a separate, different dielectric structure, while Patent Owner argues that the phrase requires that the plurality of TACs (i.e., at least two TACs) must extend through the same dielectric structure. See, e.g., Pet. 49–50; PO Resp. 18–21; Reply 2–4. In our Decision on Institution, we preliminarily construed this phrase to require that more than one (i.e., a plurality) TAC in the TAC region extends vertically through a single dielectric structure. See Inst. Dec. 17. Based upon a full record, we construe this term of claim element [8.G.iii] (i.e., “ . . . a through array contact (TAC) region formed between the first and second channel regions, wherein the TAC region comprises a plurality of through array contacts (TACs) extending vertically through the dielectric structure”) according to its plain language to require that a plurality (i.e., more than one) of TACs must extend vertically through a (i.e., at least one) dielectric structure. Under this construction, the plurality of TACs may extend through more than one dielectric structure, but the plurality of TACs must extend through at least one dielectric structure. The plain language of the claim is not satisfied if each TAC extends through a separate dielectric structure because, in this scenario, there is not a plurality of TACs that extend through a dielectric structure.” slip op. at 10
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentableNot shown unpatentable
“Resp. 31–33. Patent Owner persuasively explains, with supporting testimony by Dr. Yang, that these regions containing the interconnects and peripheral circuitry would prevent repeating the layout in the hd1 direction because the interconnects and peripheral circuitry would be located in the same region that Petitioner proposes adding the additional memory plane. Id. (citing Ex. 2004 ¶ 72). Patent Owner further persuasively explains that Toyama teaches repeating the layout in the hd2 direction, not the hd1 direction, because of the location of its interconnects and peripheral circuitry, which prevents repeating the structure in the hd1 direction. See id. at 34 (citing Ex. 1005, Figures 17E, 17F). Patent Owner persuasively explains that Toyama Figure 17F (which is an alternate view of the structure shown in Figure 17E) shows that the memory array has interconnects and driver circuits on at least the left side, which means that in a modification adding additional planes, each plane would necessarily include these interconnects and driver circuitry on the left side. Id. at 35 (citing Ex. 2004 ¶ 75). We agree with Patent Owner that Petitioner has not sufficiently shown that it would have been obvious for a POSITA to repeat the structure shown in Figure 17E in the hd1 direction due to the presence of its interconnects and peripheral circuitry.” slip op. at 34
Patent outcomesUS 10,937,806 not shown unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,937,806 - Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.All claims unpatentablePTAB · Jan 5, 2026 · IPR2024-00909 · APJ Michael T Cygan · IPR · Final written decision
Claims 1–7 and 18 are unpatentable as obvious over Toyama, based on the First Exemplary Structure and, for some limitations, the Second Modification.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“B. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art (“POSITA”) at the critical time “would have had a bachelor of science degree in electrical engineering or a similar discipline, along with 2-3 years of professional experience working with (e.g., researching, designing, or teaching) NAND 2 We apply AIA 35 U.S.C. §§ 102, 103 to the ’378 patent because it was filed after, and never claimed the benefit of an effective filing date before, March 16, 2013. Petitioner also applies AIA §§ 102 and 103. See Pet. 2, 24–26. 3 Neither party presents evidence or arguments regarding objective evidence of non-obviousness. Pet. 104; PO Resp. experience (e.g., an advanced degree may replace some of the professional experience).” Pet. 33 (citing Ex. 1003 ¶¶ 37–39). Petitioner further asserts that a POSITA “would also have been aware of and generally knowledgeable about semiconductor manufacturing and 3D NAND’s structure, its component parts, how it operates, and how it is controlled.” Id. Patent Owner does not object to such a definition. PO Resp. 13. We adopt Petitioner’s proposed level of ordinary skill, as it appears to be consistent with the Specification of the ’378 patent and the prior art of record.” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“Petitioner asserts that only the term “a staircase structure in the alternating layer” should be construed, and that the term should be construed as “a staircase structure in the alternating layer stack.” Pet. 32–33. Patent Owner does not dispute this construction, and our determination would be unaffected by Petitioner’s proposed construction. Therefore, we need not provide an express construction of this term. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (noting that “we need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy’” (quoting Vivid Techs., Petitioner asserted that all other terms should receive their plain and ordinary meaning. Pet. 33.” slip op. at 6
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“Because neither the language of claim 15 nor the Specification indicates a narrower meaning, we agree with Petitioner that the phrase “a substrate with an isolation structure” should be given its plain meaning. Patent Owner argues that the plain meaning of “with” is “having” or “inclusive of.” PO Sur-reply 2 (citing Ex. 1038, 8). Citing the same dictionary, Petitioner argues that the plain meaning of “with” includes objects that are separate. Pet. Reply 3 (stating, “In the sentence ‘Alice went to school with Bob,’ it would be nonsensical to interpret that to mean that Bob is part of Alice.”) (citing Ex. 1038, 7). The cited definition of “with” states that it may indicate “accompaniment,” such as “went there [with] her,” as well as combination (“milk [with] honey”). Ex. 1038, 7. Based on the evidence and arguments presented, we determine that the phrase “a substrate with an isolation structure” should be given its plain meaning, which includes accompaniment (A is accompanied by B) as well as combination (A is part of B, or A and B are a part of C).4” slip op. at 9
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“We are persuaded by Petitioner that the lower volume of Toyama’s dielectric fill portion teaches the isolation structure and the upper volume of Toyama’s dielectric fill portion teaches the dielectric structure. First, the structure may be the same material; i.e., SiO2. Ex. 1001, 10:37–40 (isolation structure 233 filled with SiO2), 10:46–47 (dielectric structure can include SiO2, and can include the same material as dielectric layer 230), 10:12–14 (dielectric layer 230 is formed of SiO2). Second, the ’378 patent indicates that the dielectric structure may be “aligned to” and “in contact with” the isolation structure. Id. at 10:30–36. Thus, the two structures of the ’378 patent may appear as two aligned and contacting structures; e.g., a single column of the same material. Third, the ’378 patent specification describes that the dielectric structure and a top portion of the isolation structure may be formed in the same deposition step. When etching the opening 600 that is to be filled with dielectric structure 232, “opening 600 may extend partially into STI structure 233;” i.e., “the etch process used to form opening 600 may also remove (recess) portion of the top surface of STI structure 233.” Id. at 15:12–20; Fig. 6. Then, “opening 600 can be filled with a dielectric layer 702,” which may be the same SiO2 material as the isolation structure, and “[a]s a result, dielectric structure 232 is formed.” Id. at 15:42–54. Thus, the ’378 patent describes a dielectric structure that partially replaces or re-forms, with the same material, its isolation structure. The ’378 patent does not mention whether this results in a dielectric structure that extends into the isolation structure or an isolation structure re-filled to its original height, and it would not appear to matter because both structures may be composed of the same material. The ’378 patent’s indifference to the exact boundary between dielectric structure 232 and isolation structure 233 during formation from the same material indicates that these structures need not be taught by distinct elements. applicable only if the ’378 patent describes that the isolation region and dielectric structure were formed as a single unitary structure. PO Resp. 51; PO Sur-reply 16–18. Retractable Techs. focuses on whether the two elements at issue “could be formed as an integral structure in the first instance,” not whether they were formed integrally. Retractable Techs., 653 F.3d at 1304 (“The specifications further disclose a method to couple the two structures . . . to allow some diffusion or insipient melting to occur where they touch . . . . This passage suggests that [the structures] could be formed as an integral structure in the first instance”). Retractable Techs. looks to whether the specification suggests that the claim terms require separate structures. Powell v. Home Depot U.S.A., Inc., 663 F.3d 1221, 1232 (Fed. Cir. 2011). Patent Owner’s focus on whether the claimed structures were disclosed as being separately formed disregards the issue of whether the separately claimed structures require specific methods of forming those structures. Here, as in Retractable Techs. and Powell, the Specification does not indicate any particular structure or function for the structures that results from their separate steps of deposition. Thus, as held in Retractable Techs. and Powell, the two portions of Toyama “need not be two separate parts” to teach two separate claim limitations. Retractable Techs., 635 F.3d at 1303–04. Consequently, we determine that the claim language does not support a requirement that these structures be separate and distinct. Patent Owner’s further arguments are not availing. Contrary to Patent Owner’s argument, in our “Third” point, supra, we do not state that the isolation structure and the dielectric structure are formed in the same deposition step. PO Resp. 52–53; PO Sur-reply 18; Supra at 34. We only” slip op. at 33
Patent outcomesUS 10,658,378 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,658,378 - Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.All claims unpatentablePTAB · Jan 5, 2026 · IPR2024-00788 · APJ Michael T Cygan · IPR · Final written decision
Claims 15–17, 19, and 20 are unpatentable as obvious over Toyama, Mushiga, and Mushiga with Makala.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“at the critical time “would have had a bachelor of science degree in electrical engineering or a similar discipline, along with 2-3 years of professional experience working with (e.g., researching, designing, or teaching) NAND flash memory devices, or an equivalent level of skill, knowledge, and experience (e.g., an advanced degree may replace some of the professional experience).” Pet. 27 (citing Ex. 1003 ¶¶ 36–37). Petitioner further asserts March 16, 2013. Petitioner also applies AIA §§ 102 and 103. See Pet. 2, 24–26. 3 Neither party presented evidence or arguments regarding objective evidence of non-obviousness during trial. knowledgeable about semiconductor manufacturing and 3D NAND’s structure, its component parts, how it operates, and how it is controlled.” Id. (emphasis omitted). Patent Owner does not object to this assessment. PO Resp. 12. We adopt Petitioner’s proposed level of ordinary skill, as it appears to be consistent with the specification of the ’378 patent and the prior art of record.” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“Petitioner does not dispute Patent Owner’s construction, asserting that its grounds render obvious this limitation under Patent Owner’s construction propose construction of the term “through array contact,” which was at issue in the Preliminary Response and in the parallel district court proceeding. Id. Nor have the parties indicated, in response to Board inquiry, that any relevant construction has occurred. See Paper 34. with Petitioner that Patent Owner does not dispute this aspect of the “a dielectric structure on the isolation structure” limitation in Petitioner’s assertions based on Toyama. PO Sur-reply 20–21. Patent Owner does dispute that Mushiga’s insulating spacer 586 is “on” the isolation structure. PO Resp. 70–72. However, because Petitioner relies upon a dielectric structure that includes other portions of Mushiga that Patent Owner does not dispute to be on the asserted isolation structure, the dispute is whether Petitioner is correct to include multiple components as part of a single dielectric structure, and not whether spacer 586 is on an isolation structure. Id. Because Petitioner’s assertions and our determination would be unaffected by its proposed construction, we need not construe this term. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (noting that “we need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 7
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“Patent Owner’s citations to the Specification do not support its proposed construction. Patent Owner relies on multiple embodiments, only one of which describes a substrate “with” an isolation structure. PO Resp. 21 (citing Ex. 1001, 22:27–28). For example, one of Patent Owner’s cited embodiments recites “on” an isolation region, but Patent Owner specifically argues that the “on” embodiment does not apply to the claimed “with” embodiment. Id. at 22 (denying that “the ‘with’ relationship encompasse[s] the ‘on’ relationship”). Only one of the embodiments cited is clearly within the scope of the “with” claim language, and that embodiment describes no more than the claim language itself. Ex. 1001, 22:27–28. Moreover, Figure 2, cited by Patent Owner, is an illustration “according to some embodiments,” but is not described as depicting all embodiments. Ex. 1001, 3:35–36. These other embodiments need not be included in claim 15’s “with” language because other claims (not at issue in this proceeding) specifically recite language from other embodiments. Ex. 1001, 23:20–21 (“a dielectric structure on an isolation region of the substrate”), 23:58 (“forming an isolation structure on a substrate”). Thus, the specification of the ’378 patent does not limit “a substrate with an isolation structure” in claim 15 to “part of” an isolation structure, such as in a shallow region or other partial-depth portion of the substrate. Because neither the language of claim 15 nor the Specification indicates a narrower meaning, we agree with Petitioner that the phrase “a Patent Owner argues that the plain meaning of “with” is “having” or “inclusive of.” PO Sur-reply 2 (citing Ex. 1038, 7). Citing the same dictionary, Petitioner argues that the plain meaning of “with” includes objects that are separate. Pet. Reply 3 (stating, “In the sentence ‘Alice went to school with Bob,’ it would be nonsensical to interpret that to mean that Bob is part of Alice.”) (citing Ex. 1038, 7). The cited definition of “with” states that it may indicate “accompaniment,” such as “went there [with] her,” as well as combination (“milk [with] honey”). Ex. 1038, 7. Based on the evidence and arguments presented, we determine that the phrase “a substrate with an isolation structure” should be given its plain meaning, which includes accompaniment (A is accompanied by B) as well as combination (A is part of B, or A and B are a part of C).” slip op. at 9
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“We are persuaded by Petitioner that the lower volume of Toyama’s dielectric fill portion teaches the isolation structure and the upper volume of Toyama’s dielectric fill portion teaches the dielectric structure. First, the ’378 patent indicates that both the dielectric structure and the isolation structure may be the same material; i.e., SiO2. Ex. 1001, 10:37–40 (isolation structure 233 filled with SiO2), 10:46–47 (dielectric structure can include SiO2, and can include the same material as dielectric layer 230), 10:12–14 (dielectric layer 230 is formed of SiO2). Second, the ’378 patent indicates that the dielectric structure may be “aligned to” and “in contact with” the isolation structure. Id. at 10:30–36. Thus, the two structures of the ’378 patent may appear as two aligned and contacting structures; e.g., a single column, of the same material. Third, the ’378 patent specification describes that the dielectric structure and a top portion of the isolation structure may be formed in the same deposition step. When etching the opening 600 that is to be filled with dielectric structure 232, “opening 600 may extend partially into STI structure 233;” i.e., “the etch process used to form opening 600 may also remove (recess) portion of the top surface of STI structure 233.” Id. at 15:12–20. Then, “opening 600 can be filled with a dielectric layer 702,” which may be the same SiO2 material as the isolation structure, and “[a]s a result, dielectric structure 232 is formed.” Id. at 15:42–54. Thus, the ’378 patent describes a dielectric structure that partially replaces or re-forms, with the same material, its isolation structure. The ’378 patent does not mention whether this results in a dielectric structure that extends into the isolation structure or an isolation structure re-filled to its original height, and it would material. The ’378 patent’s indifference to the exact boundary between dielectric structure 232 and isolation structure 233 during formation from the same material indicates that these need not be taught by distinct elements. We do not agree with Patent Owner that Retractable Techs. is applicable only if the ’378 patent describes that the isolation region and dielectric structure were formed as a single unitary structure. PO Resp. 50; PO Sur-reply 9. Retractable Techs. focuses on whether the two elements at issue “could be formed as an integral structure in the first instance,” not whether they were formed integrally. Retractable Techs., 653 F.3d at 1304. (“The specifications further disclose a method to couple the two structures . . . to allow some diffusion or insipient melting to occur where they touch . . . . This passage suggests that [the structures] could be formed as an integral structure in the first instance”). Retractable Techs. looks to whether the specification suggests that the claim terms require separate structures. Powell v. Home Depot U.S.A., Inc., 663 F.3d 1221, 1232 (Fed. Cir. 2011). Patent Owner’s focus on whether the claimed structures were disclosed as being separately formed disregards the issue of whether the separately claimed structures require specific methods of forming those structures. Here, as in Retractable Techs. and Powell, the Specification does not indicate any particular structure or function for the structures that results from their separate steps of deposition. Thus, as held in Retractable Techs. and Powell, the two portions of Toyama “need not be two separate parts” to teach two separate claim limitations. Retractable Techs., 635 F.3d at 1303– 04. Consequently, we determine that the claim language does not support a requirement that these structures be separate and distinct.” slip op. at 32
Patent outcomesUS 10,658,378 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,658,378 - PTAB · Dec 12, 2025 · IPR2025-01116 · APJ Christopher M Kaiser · IPR · Institution
The Board instituted IPR of claims 1–15 on all asserted grounds, finding a reasonable likelihood that claim 1 would have been obvious over Sudre, Lee, and Penven.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“determine whether to institute an inter partes review under 35 U.S.C. § 314 and 37 C.F.R. § 42.4(a). Inter partes review may not be instituted unless “the information presented in the petition filed under [35 U.S.C.] section 311 and any response filed under [35 U.S.C.] section 313 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). “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) (2023). In other words, a decision to institute under § 314 may not institute on fewer than all claims challenged in the petition. SAS Inst., Inc. v. Iancu, 138 S. Ct. 1348, 1359–60 (2018). In addition, if the Board institutes trial, it will “institute . . . on all grounds in the petition.” PTAB Consolidated Trial Practice Guide, 5–6 (Nov. 2019)1 (“CTPG”); see also PGS Geophysical AS v. Iancu, 891 F.3d 1354, 1360 (Fed. Cir. 2018) (interpreting the statute to require “a simple yes-” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“had at least (1) a Bachelor’s Degree (or higher) in material science, materials engineering, mechanical engineering, textile engineering, or a related field, and (2) a minimum of two years of working experience in textiles engineering, fibers and textiles manufacturing, or a related field.” Pet. 4 (citing Ex. 1003 ¶¶ 21–22). Petitioner also argues that “[a]dditional education could substitute for professional experience, and vice versa.” Id. On the present record, Patent Owner does not contest Petitioner’s proposed level of ordinary skill. Prelim. Resp. 25–26. For purposes of this Decision, we adopt Petitioner’s assessment of the level of ordinary skill in the art, as it appears consistent with the ’566 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Both parties argue that no claim terms require express construction at this stage of the proceeding. Pet. 3; Prelim. Resp. 26. On the present record, we agree. 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))). To the extent the parties’ arguments regarding unpatentability do address claim construction issues, we address these issues below.” slip op. at 10
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner
“articulated a reason why a person of ordinary skill in the art would have combined the teachings of Sudre, Lee, and Penven. Prelim. Resp. 60–63. In particular, Patent Owner argues that a person of ordinary skill in the art “would not have been motivated to look into Penven to modify the teachings of Lee because Lee and Penven disclose substantially different structures.” Id. at 60–61. This argument does not address Petitioner’s proposed reason to combine, which looks to Lee and Penven each to modify Sudre, not to Penven to modify Lee. See Pet. 79–81. In addition, “[c]ombining the teachings of references does not involve an ability to combine their specific structures.” In re Nievelt, 482 F.2d 965, 968 (CCPA 1973). In other words, “[t]he test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference . . . . Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art.” In re Keller, 642 F.2d 413, 425–26 (CCPA 1981). Petitioner provides “some articulated reasoning with some rational underpinning” to combine the teachings of Sudre with those of Lee and Penven. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007). In particular, Petitioner directs us to Sudre’s teaching of “a method for manufacturing PMC,” to Sudre’s lack of teaching of “specific parameters, such as warp thread size and spacing” to satisfy the “particular requirements” of its fabric. Pet. 79 (citing Ex. 1003 ¶¶ 248–250; Ex. 1004, 1:2–5, 6:14–17). As Petitioner points out, id. at 79–80, Lee and Penven provided yarn diameters and loop diameters that were conventional, and there is evidence of record that a person of ordinary skill in the art would have used these conventional diameters in constructing Sudre’s paper machine clothing. Ex. 1003 ¶¶ 258–261, 263–266; Ex. 1006, 3:64–66.” slip op. at 14
Claim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,261,566
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.