• Meta Platforms, Inc. v. Sitnet LLCAdverse judgment
  PTAB · Jul 15, 2026 · IPR2026-00100 · APJ Thu A Dang · IPR · Adverse judgment

  The Board granted adverse judgment against SitNet after its disclaimer left no challenged claims remaining in the instituted trial.

  RulingsAdverse judgment

  • Adverse judgmentAdverse judgmentGranted

    “judgment include: . . . [c]ancellation or disclaimer of a claim such that the party has no remaining claim in the trial.” 37 C.F.R. § 42.73(b)(2). “The application of the [adverse judgment] rule on its face does not turn on the patentee’s characterization of its own request.” Arthrex, Inc. v. Smith & Nephew, Inc., 880 F.3d 1345, 1349 (Fed. Cir. 2018). In this case, Patent Owner’s disclaimer of all claims of the ’290 patent leaves no claims remaining in the trial. Although Patent Owner argues that “it was filed to conserve the limited resources of the Board and the Parties in light of the fact that the ’290 Patent is no longer involved in any copending litigation” (Ex. 3001), we deem such argument not a persuasive reason as to why we should not apply § 42.73(b)(2), or why termination is more appropriate. Pursuant to 37 C.F.R. § 42.73(b)(2), we construe Patent Owner’s disclaimer of all claims at trial as a request for adverse judgment, which we grant.” slip op. at 3

  None
  Patents in suitUS 10,117,290
• Kubota North America Corporation v. Vermeer Manufacturing CompanySome claims unpatentable
  PTAB · Jun 30, 2026 · IPR2025-00169 · APJ Meredith C Petravick · IPR · Final written decision

  Claims 50–54 are unpatentable as obvious over KR996 and JP705; claims 55–63, 68, 69, and 80–85 were not shown unpatentable over KR996, JP705, Bares, and Beltrami.

  RulingsFinal written decision

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

    “(“This language is merely exemplary, using reference numerals to refer to the embodiment’s features and qualifying ‘single weldment’ as referring ‘generally’ to specific embodiments.”). The Iowa District Court reached the same conclusion. See Ex. 1020 at 4 (holding that “‘mainframe’ will be given its plain and ordinary meaning and does not require a single weldment” (emphasis added)), cited at Pet. Init. CC Br. 2; see also 37 C.F.R. § 42.100(b) (“Any prior claim construction determination concerning a term of the claim in a civil action, or a proceeding before the International Trade Commission, that is timely made of record in the inter partes review proceeding will be considered.”).” slip op. at 35

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

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness analysis includes consideration and weighing of Patent Owner’s objective indicia of non-obviousness.” slip op. at 57

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableNot shown unpatentableMixed

    “e) Conclusion as to the Independent Claim 50 For the reasons discussed above, the evidence presented by Petitioner” slip op. at 67

  • ExcludeMotion to exclude, grantedGranted in part

    “For these reasons, we are persuaded by Petitioner to exclude, as” slip op. at 19

  Patent outcomesUS 9,321,386 mixed
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,321,386
• Kubota North America Corporation v. Vermeer Manufacturing CompanyAll claims unpatentable
  PTAB · Jun 30, 2026 · IPR2025-00168 · APJ Meredith C Petravick · IPR · Final written decision

  The Board held claims 31–49, 70–79, 86, and 87 unpatentable under §103 over KR996 and JP705, with Bares added for claims 70–79.

  RulingsFinal written decision

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

    “Pet. Init. CC Br. 3 (stating that “by including the term ‘generally’ in a statement, the feature (i.e., single weldment) is expressly identified as merely included in some, but not all embodiments”); PO Init. CC Br. 3 (“This language is merely exemplary, using reference numerals to refer to the embodiment’s features and qualifying ‘single weldment’ as referring ‘generally’ to specific embodiments.”). The Iowa District Court reached the same conclusion. See Ex. 1020 at 4 (holding that “‘mainframe’ will be given its plain and ordinary meaning and does not require a single weldment” (emphasis added)), cited at Pet. Init. CC Br. 2; see also 37 C.F.R. § 42.100(b) (“Any prior claim construction determination concerning a term of the claim in a civil action, or a proceeding before the International Trade Commission, that is timely made of record in the inter partes review proceeding will be considered.”). Turning to the prosecution history, neither Petitioner nor Patent Owner has highlighted any specific statements that impact the scope of the term “mainframe.” And from our independent review, we do not discern any such statements. For these reasons, the intrinsic evidence as a whole supports construing “mainframe” as a primary supporting structure.” slip op. at 33

  • Skill levelOther

    “B. Level of Ordinary Skill in the Art The level of ordinary skill in the art is “a prism or lens” through which” slip op. at 20

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
  • Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia no nexusDecided for petitioner

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness analysis includes consideration and weighing of Patent Owner’s objective indicia of non-obviousness.” slip op. at 55

  Patent outcomesUS 9,321,386 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,321,386
• Kubota North America Corporation v. Vermeer Manufacturing CompanySome claims unpatentable
  PTAB · Jun 30, 2026 · IPR2025-00167 · APJ Meredith C Petravick · IPR · Final written decision

  Claims 1–13, 21, 22, 64, and 65 are unpatentable over the asserted grounds; claims 15, 17, 19, 20, 23–30, 66, and 67 were not shown unpatentable over KR996, JP705, and Beltrami.

  RulingsFinal written decision

  • ExcludeMotion to exclude, deniedDenied

    “B. Analysis “The moving party has the burden of proof to establish that it is” slip op. at 9

  • Skill levelOther

    “B. Level of Ordinary Skill in the Art We review the grounds of unpatentability in view of the” slip op. at 21

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

    “lexicographical, we agree with the parties that “mainframe” is not limited to a single weldment. Pet. Init. CC Br. 1; PO Init. CC Br. 1–2. Instead, a single-weldment “mainframe” is merely one disclosed embodiment. See Pet. Init. CC Br. 3 (stating that “by including the term ‘generally’ in a statement, the feature (i.e., single weldment) is expressly identified as merely included in some, but not all embodiments”); PO Init. CC Br. 3 (“This language is merely exemplary, using reference numerals to refer to the embodiment’s features and qualifying ‘single weldment’ as referring ‘generally’ to specific embodiments.”). The Iowa District Court reached the same conclusion. See Ex. 1020 at 4 (holding that “‘mainframe’ will be given its plain and ordinary meaning and does not require a single weldment” (emphasis added)), cited at Pet. Init. CC Br. 2; see also 37 C.F.R. § 42.100(b) (“Any prior claim construction determination concerning a term of the claim in a civil action, or a proceeding before the International Trade Commission, that is timely made of record in the inter partes review proceeding will be considered.”).” slip op. at 33

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

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness analysis includes consideration and weighing of Patent Owner’s objective indicia of non-obviousness.” slip op. at 55

  Patent outcomesUS 9,321,386 mixed
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,321,386
• Kubota North America Corporation v. Vermeer Manufacturing CompanyAll claims unpatentable
  PTAB · Jun 30, 2026 · PGR2025-00016 · APJ Eric C Jeschke · PGR · Final written decision

  Claims 4–14 are unpatentable: claims 4 and 7–12 as anticipated by KR996, claims 5–6 as obvious over KR996 and JP705, and claims 13–14 as obvious over KR996 and Bares.

  RulingsFinal written decision

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

    “2. The Reasons to Combine KR996 and JP705 Petitioner provides reasons to combine KR996 with JP705. See” slip op. at 73

  • Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia no nexusObjective indicia outweighedDecided for petitioner

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness analysis includes consideration and weighing of Patent Owner’s objective indicia of non-obviousness.” slip op. at 53

  • ExcludeMotion to exclude, grantedGranted in part

    “For these reasons, we are persuaded by Petitioner to exclude, as” slip op. at 27

  Patent outcomesUS 12,098,063 unpatentable
  § 103 obviousnesscites Phillips
  Patents in suitUS 12,098,063
• Kubota North America Corporation v. Vermeer Manufacturing CompanyAll claims unpatentable
  PTAB · Jun 30, 2026 · IPR2025-00381 · APJ Eric C Jeschke · IPR · Final written decision

  Claims 1–10 are unpatentable: claims 1–8 and 10 are anticipated by KR996, and claim 9 is obvious over KR996 and Bares.

  RulingsFinal written decision

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

    “2. Independent Claim 1 Petitioner contends that KR996 both anticipates and renders obvious independent claim 1. Pet. 23–46. To support its arguments, Petitioner identifies certain passages in the cited references and explains the significance of each passage with respect to the corresponding claim limitation. Id. Patent Owner argues that KR996 does not disclose a “loader support” and thus fails to disclose limitations requiring “linkage[s]” and an “actuator” attached to the “loader support.” See PO Resp. 37–40; PO Sur-reply 20. In addition, Patent Owner presents evidence of objective indicia of nonobviousness. See PO Resp. 51–68; PO Sur-reply 23–27. We address each issue in turn. a. The Loader Support Limitations Claim 1 recites, in relevant part, “[1.3] a loader support having a first side and a second side . . . ; [1.5] a first linkage connected to the first side of the loader support . . . ; [1.6] a second linkage connected to the first side of the loader support . . . ; [1.7] a second actuator for raising the loader, the second actuator being connected to the loader support.” Ex. 1001, 6:56, 6:60–7:1 (collectively, the “loader support limitations”). As to the recitation of “a loader support having a first side and a second side,” Petitioner provides the following annotated version of Figure 9 of KR996: Pet. 30. In the annotated version of Figure 9 of KR996 above, Petitioner added (1) red text and arrows identifying a “loader support,” a “first side of loader support,” and a “second side of loader support” and (2) blue text identifying a “loader.” Id. Petitioner adds that “the loader support includes the portions of the frame of the KR996 vehicle that when in operation, support the attached loader unit 40 having loader arms of the booms 44.” Pet. 29. Petitioner also states that “KR996’s loader support includes the bracket to which the link 45 and boom cylinder 46 attach, as well as the frame protrusion, connected to the bracket, to which the forward link attaches.” Id. (citing Velinsky Pet. Decl. ¶ 72).” slip op. at 32

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

    “2. Dependent Claim 9 Petitioner contends that KR996, modified based on Bares, satisfies the additional limitations of claim 9. Pet. 60–69. To support its arguments, Petitioner identifies certain passages in the cited references and explains the significance of each passage with respect to the corresponding claim limitation. Id. Petitioner also articulates reasons to combine the relied-upon aspects of KR996 and Bares and explains why there would have been a reasonable expectation of success. Pet. 62–65. Patent Owner argues that one of ordinary skill in the art would not have had reason to combine KR996 and Bares. See PO Resp. 41–50; PO Sur-reply 22–23. Patent Owner also relies on its prior arguments that KR996 does not disclose the “loader support” limitations in independent claim 1. See PO Resp. 50. In addition, Patent Owner relies on the same evidence of objective indicia of nonobviousness discussed above. See PO Resp. 51–68; PO Sur-reply 21–27. We address each issue in turn. a. The Reasons to Combine KR996 and Bares Petitioner presents reasons why one of ordinary skill in the art would have combined KR996 and Bares and why the proposed combination would have had a reasonable expectation of success. See Pet. 62–65; Velinsky Pet. Decl. ¶¶ 157–162. After discussing why KR996 and Bares are analogous art to the claimed invention, Petitioner states that one of ordinary skill in the art “would have been motivated to combine the teachings of Bares with KR996 to produce a predictable and beneficial configuration of a tracked vehicle” in that “[t]he simple substitution of Bares’ track assembly for the wheels in the KR996 vehicle would have been predictable with a reasonable expectation of success that both KR996 and Bares relate to similar vehicle types with a similar mainframe having a drive mechanism attached thereto.” Pet. 63 (citing Velinsky Pet. Decl. ¶¶ 158–162). Petitioner asserts that “designing this vehicle type with a drive” slip op. at 64

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

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness analysis includes consideration and weighing of Patent Owner’s objective indicia of non-obviousness. In order to accord substantial weight to secondary considerations in an obviousness analysis, “the evidence of secondary considerations must have a ‘nexus’ to the claims, i.e., there must be ‘a legally and factually sufficient connection’ between the evidence and the patented invention.” Henny Penny Corp. v. Frymaster LLC, 938 F.3d 1324, 1332 (Fed. Cir. 2019) (quoting Demaco Corp. v. F. Von Langsdorff Licensing Ltd., 851 F.2d 1387, 1392 (Fed. Cir. 1988)); Quanergy Sys., Inc. v. Velodyne Lidar USA, Inc., 24 F.4th 1406, 1417 (Fed. Cir. 2022). Although the patent owner bears the initial burden of proving a nexus (WMS Gaming Inc. v. Int’l Game Tech., 184 F.3d 1339, 1359 (Fed. Cir. 1999)), a presumption of nexus may be appropriate if the patent owner shows “the asserted objective evidence is tied to a specific product and that product ‘embodies the claimed features, and is coextensive with them.’” Polaris Indus, Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1072 (Fed. Cir. 2018) (quoting Brown & Williamson Tobacco Corp. v. Philip Morris Inc., 229 F.3d 1120, 1130 (Fed. Cir. 2000) (emphasis added)); Quanergy, 24 F.4th at 1417. On the other hand, “[w]hen the [product] is not coextensive with the patented invention—for example, if the patented invention is only a component of a commercially successful machine or process,” the patent owner is not entitled to a presumption of nexus. Demaco, 851 F.2d at 1392. A patent owner may establish nexus, either through (1) the use of a rebuttable presumption that arises when certain conditions are met or (2) a direct showing of nexus. In the first, a patent owner may rely on a rebuttable presumption of nexus as follows:” slip op. at 43

  • ExcludeMotion to exclude, grantedMotion to exclude, deniedGranted in part

    “2. Analysis “The moving party has the burden of proof to establish that it is entitled to the requested relief.” 37 C.F.R. § 42.20. Exhibit 1005 is an English language translation of Korean Patent No. 10-1041996. Exhibit 1006 is an English language translation of Japanese document JP2004-17705A. Exhibit 1014 is an English language translation of Korean Patent No. 10-1023528. A Certification of Translation signed by Takashi Maeshiro of HC Language Solutions, Inc., accompanies each of Exhibits 1005, 1006, and 1014. Ex. 1005 at 28; Ex. 1006 at 16; Ex. 1014 at 16. Each Certification of Translation is worded substantially the same except for the references to the document at issue and the source language being either Korean or Japanese. Exhibit 1005’s Certification of Translation, for example, states: I, Takashi Maeshiro, on behalf of HC Language Solutions, Inc., do solemnly and sincerely declare, to the best of my knowledge and belief, that the attached text represents a translation of Korean Patent No. 10-1041996, that the translation was performed by HC Language Solutions, Inc., and that the translation represents a true, correct, and faithful translation from Korean to English in a form that reflects the intention and meaning of the original text. I hereby declare that all statements made herein of my own knowledge are true and that all statements made on information and belief are believed to be true; and further that these statements were made with the knowledge that willful false statements and the like so made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the United States Code. Ex. 1005 at 28 (emphasis added).” slip op. at 17

  Patent outcomesUS 11,465,891 unpatentable
  § 102 anticipation§ 103 obviousnesscites Phillips · KSR
  Patents in suitUS 11,465,891
• Kubota North America Corporation v. Vermeer Manufacturing CompanySome claims unpatentable
  PTAB · Jun 30, 2026 · IPR2025-00171 · APJ Eric C Jeschke · IPR · Final written decision

  Claims 1–13 and 28 are unpatentable over KR996; claims 14–16 and 19–27 were not shown unpatentable over Bares and Beltrami.

  RulingsFinal written decision

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

    “(“This language is merely exemplary, using reference numerals to refer to the embodiment’s features and qualifying ‘single weldment’ as referring ‘generally’ to specific embodiments.”). The Iowa District Court reached the same conclusion. See Ex. 1020 at 4 (holding that “‘mainframe’ will be given its plain and ordinary meaning and does not require a single weldment” (emphasis added)), cited at Pet. Init. CC Br. 2; see also 37 C.F.R. § 42.100(b) (“Any prior claim construction determination concerning a term of the claim in a civil action, or a proceeding before the International Trade Commission, that is timely made of record in the inter partes review proceeding will be considered.”). Turning to the prosecution history, neither Petitioner nor Patent Owner has highlighted any specific statements that impact the scope of the term “mainframe.” And from our independent review, we do not discern any such statements. For these reasons, the intrinsic evidence as a whole supports construing “mainframe” as a primary supporting structure.” slip op. at 35

  • Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia no nexusNot shown unpatentable

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness analysis includes consideration and weighing of Patent Owner’s objective indicia of non-obviousness.” slip op. at 54

  • ExcludeMotion to exclude, grantedMotion to exclude, deniedGranted in part

    “For these reasons, we are persuaded by Petitioner to exclude, as” slip op. at 28

  Patent outcomesUS 10,202,266 mixed
  Claim construction§ 103 obviousnesscites Phillips
  Patents in suitUS 10,202,266
• Kubota North America Corporation v. Vermeer Manufacturing CompanySome claims unpatentable
  PTAB · Jun 30, 2026 · IPR2025-00170 · APJ Eric C Jeschke · IPR · Final written decision

  Claims 1–18 are unpatentable over KR996 and the KR996/Bares combination; Petitioner did not prove claims 19–36 unpatentable over KR996, Bares, and Beltrami.

  RulingsFinal written decision

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

    “(10) Conclusion as to Objective Indicia We have considered, as a whole, all of Patent Owner’s arguments and admissible evidence concerning secondary considerations. If we were to presume nexus, we give some weight to Patent Owner’s admissible evidence of industry praise and skepticism at the time of invention. d. Conclusion as to Claim 1 For the reasons discussed above (§§ II.F.2.a–b), the evidence” slip op. at 62

  • Obviousness (§103) › Objective indicia / secondary considerationsObjective indicia outweighedDecided for petitioner

    “probative and cogent evidence in the record” and “may often establish that an invention appearing to have been obvious in light of the prior art was not.” Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1349 (Fed. Cir. 2012). Thus, notwithstanding what the teachings of the prior art would have suggested to one skilled in the art, secondary considerations (objective evidence of non-obviousness) may lead to a conclusion that the challenged claims would not have been obvious. In re Piasecki, 745 F.2d 1468, 1471–72 (Fed. Cir. 1984). Our obviousness” slip op. at 52

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

    “lexicographical, we agree with the parties that “mainframe” is not limited to a single weldment. Pet. Init. CC Br. 1; PO Init. CC Br. 1–2. Instead, a single-weldment “mainframe” is merely one disclosed embodiment. See Pet. Init. CC Br. 3 (stating that “by including the term ‘generally’ in a statement, the feature (i.e., single weldment) is expressly identified as merely included in some, but not all embodiments”); PO Init. CC Br. 3 (“This language is merely exemplary, using reference numerals to refer to the embodiment’s features and qualifying ‘single weldment’ as referring ‘generally’ to specific embodiments.”). The Iowa District Court reached the same conclusion. See Ex. 1020 at 4 (holding that “‘mainframe’ will be given its plain and ordinary meaning and does not require a single weldment” (emphasis added)), cited at Pet. Init. CC Br. 2; see also 37 C.F.R. § 42.100(b) (“Any prior claim construction determination concerning a term of the claim in a civil action, or a proceeding before the International Trade Commission, that is timely made of record in the inter partes review proceeding will be considered.”). Turning to the prosecution history, neither Petitioner nor Patent Owner has highlighted any specific statements that impact the scope of the term “mainframe.” And from our independent review, we do not discern any such statements. For these reasons, the intrinsic evidence as a whole supports construing “mainframe” as a primary supporting structure.” slip op. at 33

  • ExcludeMotion to exclude, grantedMotion to exclude, deniedMixed

    “2. Analysis “The moving party has the burden of proof to establish that it is entitled to the requested relief.” 37 C.F.R. § 42.20. a. Exhibits 1005, 1006, and 1014 Exhibit 1005 is an English language translation of Korean Patent No. 10-1041996. Exhibit 1006 is an English language translation of Japanese document JP2004-17705A. Exhibit 1014 is an English language translation of Korean Patent No. 10-1023528. A Certification of Translation signed by Takashi Maeshiro of HC Language Solutions, Inc., accompanies each of Exhibits 1005, 1006, and 1014. Ex. 1005 at 28; Ex. 1006 at 16; Ex. 1014 at 16. Each Certification of Translation is worded substantially the same except for the references to the document at issue and the source language being either Korean or Japanese. Exhibit 1005’s Certification of Translation, for example, states: I, Takashi Maeshiro, on behalf of HC Language Solutions, Inc., do solemnly and sincerely declare, to the best of my knowledge and belief, that the attached text represents a translation of Korean Patent No. 10-1041996, that the translation was performed by HC Language Solutions, Inc., and that the translation represents a true, correct, and faithful translation from Korean to English in a form that reflects the intention and meaning of the original text. I hereby declare that all statements made herein of my own knowledge are true and that all statements made on information and belief are believed to be true; and further that these statements were made with the knowledge that willful false statements and the like so made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the United States Code. Ex. 1005 at 28 (emphasis added). Patent Owner argues that the Certifications of Translation do not” slip op. at 18

  Patent outcomesUS 9,975,750 mixed
  Claim construction§ 103 obviousnesscites Phillips
  Patents in suitUS 9,975,750
• Yealink (USA) Network Technology Co. Ltd. / Yealink Network Technology Co., Ltd. v. Barco N.V.All claims unpatentable
  PTAB · Apr 7, 2026 · IPR2024-01439 · APJ Frederick C Laney · IPR · Final written decision

  Claims 1–11 and 13–21 are unpatentable under § 103 based on Ono and Corbett and Uchida and Grimshaw; the Board did not find Ichieda unpatentable.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art Petitioner contends that a person having ordinary skill in the art would have had at least a Master’s Degree in Electrical Engineering with . . . five years of work experience in computer science and embedded systems, or Master’s Degree in Computer Science with . . . five years of work experience in electrical and computer engineering and embedded systems. Additional educational experience could substitute for some of the work experience. level of skill in the art.” PO Resp. 10. We adopt Petitioner’s proposed definition of a person of ordinary skill in the pertinent art, as it is consistent with the ’951 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 7

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

    “determine that none of the claim terms the parties provide constructions for require an express construction in this proceeding. See Realtime Data LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019). The parties do appear to disagree on the meaning of “trigger,” however. Although neither party actually identifies that term as needing interpretation and neither party actually provides a claim construction analysis to support its respective position, the parties do dispute whether the evidence presented shows a “trigger,” both presumably giving that term its plain and customary meaning. In other words, while both parties appear to agree “trigger” carries its plain meaning, in application, the parties’ dispute regarding the particular limitations including that term appears to turn, not over what the evidence discloses, but only on whether the disclosure satisfies the plain meaning of “trigger” (see infra § II.E.2). Accordingly, while we apply the plain meaning of “trigger” in this proceeding, and in doing so, we address which party has properly applied the plain meaning and, in doing that, we address the scope properly afforded to “trigger.” That analysis, however, is done below in the context of the limitation in which this issue arises (see id.).” slip op. at 8

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

    “has now been developed, and in view of both parties’ arguments, we find Petitioner has persuasively shown that modifying Ono’s peripheral device (i.e., communications module 44) to include an input device/physical actuator like the one described for Ono’s remote controller 69 to control the display of image data from a particular user’s computer would have been obvious to a skilled artisan at the time of the invention. More specifically, Petitioner has shown persuasively Ono shows that the use of an input device/physical actuator to send a signal that causes a participant’s computer to transmit and control the image data presented on a shared display in an image display system was a known technique (see Ex. 1005 ¶¶ 7, 44–48, 66– 71, 77–78, 80–89, 144, Figs. 3, 6, 8, 9; Ex. 1002 ¶¶ 85–100, 121–127) and available location for such an input device/physical actuator to initiate the transmission of data (see Ex. 1007 ¶¶ 6, 18, 20, 22–23, 26, 28, 46, Fig. 1; Ex. 1002 ¶¶ 92–100). Petitioner has also persuasively shown that a skilled artisan recognized benefits to giving a participant the ability to locally control the display of their computer’s image data. See Ex. 1002 ¶¶ 87–91; Ex. 1008 ¶¶ 4, 19–20, 27–28; Ex. 1009 ¶¶ 10–13, 39–10, 70–72. When Ono and Corbett are considered together as a whole from the perspective of a skilled artisan, therefore, it is clear that applying a similar input device/physical actuator to Ono’s peripheral device would have been recognized to result in the benefit of providing a participant with the same ability to send a signal that causes a participant’s computer to transmit and control the image data presented on a shared display from their computer within an image display system. As a result, a motivation has been established because the combination is an application of a known technique to derive a known benefit using prior art elements according to their established functions. Intel Corp. v. PACT XPP Schweiz AG, 61 F.4th 1373, 1380 (Fed. Cir. 2023).” slip op. at 24

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

    “that, from their perspective, the plain meaning of the term “trigger” does not exclude intervening steps between a user’s action on an input device and the ultimate transfer of the user selected arbitrary media content. Pet. Reply 11– 12 (indicating that “trigger” encompasses “a process that begins with and thus is triggered by a user pressing a button followed by an ‘image transfer’ from a PC to a projector”). For its part, Patent Owner maintains (at least implicitly) that intervening steps are excluded from the plain meaning. Neither party addresses with more specificity why, or why not, the scope of “trigger” supports their positions, however. Having now the complete record before us, we find that out preliminary assessment was wrong because the plain meaning of the term “trigger” does not exclude intervening steps between the cause-and-effect relationship of the trigger and the result it is intended to cause. Take, for example, a simple gun. Pulling the “trigger” to fire a gun necessarily includes intervening steps to occur: the trigger releases a hammer that, in turn, contacts a blasting cap within a bullet casing, which is what actually causes the gunpowder to ignite (i.e., fire) and expel the bullet. And there is no evidence in this record to suggest that this customary understanding of the word “trigger” is any different in the electrical arts, other than the trigger and result are generally electrical in nature, rather than mechanical. We find no clear disavowal of claim scope within the intrinsic record of the ’951 patent to indicate that the term “trigger” was intended to be understood any differently to exclude any intervening steps between a user’s action on an input device and the resulting transfer of user selected arbitrary media content. intervening steps would exist because the input device does not actually do the transferring of the media content; instead, the claims recite the transferring is “from the transmitter to the wireless communications network and [then] to the base node.” See Ex. 1001, 11:3–48, 27:62–28:1 (claim 1), 28:62–67 (claim 9), 29:42–46 (claim 16), 30:36–44 (claim 21) (emphasis added). A skilled artisan would have recognized that there would be intervening steps between the input device being acted upon and the content being displayed by base node’s display. See Ex. 1083 ¶¶ 11–12. In the claims, the input device is analogous to a gun’s trigger, the user carrying out a user action on the input device is analogous to pulling a gun’s trigger, and the transfer of user selected arbitrary media content is analogous the gun expelling a bullet. In both cases, there can be, and usually are, intervening steps, moreover, in both cases, inadvertent things can happen that may prevent the intended result (e.g., in the case of a gun, the hammer can jam; in the case of an input device, a connection can be rejected). Nevertheless, in both cases, the trigger is the thing that initiates an automated process that leads to a particular result, unless a conditional error occurs.” slip op. at 31

  Patent outcomesUS 11,422,951 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,422,951
• Yealink (USA) Network Technology Co. Ltd. / Yealink Network Technology Co., Ltd. v. Barco N.V.All claims unpatentable
  PTAB · Apr 7, 2026 · IPR2024-01438 · APJ Frederick C Laney · IPR · Final written decision

  Claims 1, 4, 5, 8, 14, 16, and 18–20 are unpatentable under § 103 based on the five asserted obviousness grounds.

  RulingsFinal written decision

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

    “550 U.S. at 418 (citing In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006) (“[R]ejections on obviousness grounds cannot be sustained by mere conclusory statements; instead, there must be some articulated reasoning with some rational underpinning to support the legal conclusion of obviousness.” (alteration in original)). This search for answers about whether the claimed subject matter would have been obvious to a skilled artisan at the time of the invention applies “an expansive and flexible art elements would have been obvious is determined by whether the improvement is more than the predictable use of prior art elements according to their established functions. Id. at 417. Reaching this conclusion, however, “requires more than a mere showing that the prior art includes separate references covering each separate limitation in a claim under examination.” Unigene Labs., Inc. v. Apotex, Inc., 655 F.3d 1352, 1360 (Fed. Cir. 2011). “Rather, obviousness requires the additional showing that a person of ordinary skill at the time of the invention would have selected and combined those prior art elements in the normal course of research and development to yield the claimed invention.” Id.” slip op. at 6

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

    “3. Conclusion as to Secondary Considerations We have considered all of Patent Owner’s arguments and evidence concerning secondary considerations. We give Patent Owner’s evidence regarding its revenue and profits from the ClickShare product line little weight. We give some weight to Patent Owner’s evidence of licensing. We, however, do not find the licensing evidence outweighs Petitioner’s showing of obviousness.” slip op. at 86

  Patent outcomesUS 11,258,676 unpatentable
  § 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,258,676

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.