• Tesla, Inc. v. Intellectual Ventures II LLCNo claims unpatentable
  PTAB · Jun 22, 2026 · IPR2025-00217 · APJ Frederick C Laney · IPR · Final written decision

  The Board held claims 1–5, 10–15, and 20 not unpatentable under four §103 grounds because the petitioner did not establish the claimed enabled-accumulation indication or single-channel combination.

  RulingsFinal written decision

  • BurdenNot shown unpatentable

    “onset to show with particularity why the patent it challenges is 1 The Leahy-Smith America Invents Act (“AIA”), Pub. L. No. 112-29, 125 Stat. 284 (2011), amended 35 U.S.C. § 103, effective March 16, 2013. Because the application from which the ’153 patent issued claims priority to an application filed before this date, the pre-AIA version of § 103 applies. 2 US 6,334,047 B1, iss. Dec. 25, 2001 (Ex. 1009). 3 US 2001/0036238 A1, pub. Nov. 1, 2001 (Ex. 1010) 4 US 2004/0190485 A1, pub. Sept. 30, 2004 (Ex. 1005). 5 US 2004/0077370 A1, pub. Apr. 22, 2004 (Ex. 1008). 6 US 6,600,772 B1, iss. July 29, 2003 (Ex. 1004). 7 US 6,529,741 B1, iss. Mar. 4, 2003 (Ex. 1007). unpatentable.” Harmonic Inc. v. Avid Tech., Inc., 815 F.3d 1356, 1363 (Fed. Cir. 2016) (citing 35 U.S.C. § 312(a)(3) (requiring inter partes review petitions to identify “with particularity . . . the evidence that supports the grounds for the challenge to each claim”)). This burden of persuasion never shifts to the patent owner. See Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015). Moreover, a petitioner should not “place the burden on [the Board] to sift through information presented by the Petitioners, determine where each element [of the challenged claims] is found in [the cited references], and identify any differences between the claimed subject matter and the teachings of [the cited references].” Google Inc. v. EveryMD.com LLC, IPR2014-00347, Paper 9 at 25 (PTAB May 22, 2014).” slip op. at 5

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “A. Level of Ordinary Skill in the Art Petitioner asserts that ordinarily skilled artisans “would have a bachelor’s degree in electrical engineering, computer engineering, computer science, or equivalent training, and approximately two years of experience working in the field of wireless communication systems or design of similar communication systems.” Pet. 15. Petitioner’s proposed definition, which Patent Owner does not dispute, appears reasonable and consistent with the asserted prior art and the ’153 patent. Therefore, we adopt it as the ordinary level of skill of an artisan in the field of the patented technology for our analysis below.” slip op. at 7

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

    “apparent agreement between the parties: “TPC command accumulation” refers to a process that collects and uses TPC commands from a network device to cumulatively affect transmission power. And having studied the intrinsic record of the ’153 patent, we are in accord. But, we decline to further limit the construction of “TPC command accumulation” in the manner proposed by either party––i.e., (1) each TPC command adjustment must be summed to cumulatively affect transmission power (as proposed by Petitioner) or (2) a TPC command value must be added to an integrator. Although both parties are able to point to disclosures in the ’153 Patent where the TPC command accumulation of an exemplary embodiment is described as using an integrator and/or summing each TPC command adjustment to cumulatively affect a UE’s transmission power (PO Resp. 16 (citing Ex. 1001, 3:39–43, 7:15–29, 9:27–42; Ex. 2016 ¶¶ 35–42); Pet. Reply 4–5 (citing Ex. 1001, 3:39–43, 7:2–6, 7:8–22, 9:28–40)), neither party has demonstrated persuasively that the intrinsic record of the ’153 Patent demonstrates a clear intent to limit “TPC command accumulation” to those particular embodiments.” slip op. at 11

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundReasonable expectation not foundNot shown unpatentable

    “A rationale supports obviousness only where the proffered benefit would flow from the specific modification proposed; a benefit that the prior art realizes in a different structural context does not, without more, establish that the same benefit would result from inserting one reference’s element into the other. On this record, the nexus between Khan’s benefits and Petitioner’s “other bits” modification is missing.” slip op. at 40

  Patent outcomesUS 10,952,153 not shown unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,952,153
• X Corp. v. Sterling Computers CorporationAll claims unpatentable
  PTAB · Jun 9, 2026 · IPR2025-00299 · APJ Bach V Hoang · IPR · Final written decision

  Claims 1–22 are unpatentable as obvious over the stated Dumais-based and Kircher/Krug grounds; Patent Owner’s and Petitioner’s motions to exclude are dismissed as moot.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Our Institution Decision adopted Petitioner’s definition of a person of ordinary skill in the art. Inst. Dec. 8–9. In its response, Patent Owner adopts Petitioner’s proposed level of ordinary skill. See PO Resp. 14–15 (“Patent Owner and its expert adopt the Board’s definition for purposes of this Response”). Having considered the record, we continue to adopt Petitioner’s proposed level of skill, as articulated above. We are satisfied that Petitioner’s proposal comports with the level of skill necessary to understand and implement the teachings of the ’217 Patent. Accord Inst. Dec. 8–9.” slip op. at 9

  • Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)No construction neededNot reached

    “1. “computer program modules” The parties dispute whether four “computer program modules comprising” (1) “a monitoring module,” (2) “a first relevance measurement module,” (3) “a second relevance measurement module,” and (4) “a relevance analysis module” (collectively, “module limitations”) invoke 35 U.S.C. § 112 ¶ 6 and should be treated as means-plus-function limitations. See Pet. 8–18; PO Resp. 15–18; Pet. Reply 3–5; PO Sur-reply 4–7. However, the parties do not argue that the construction of these terms affects the analysis of Petitioner’s challenges. See PO Resp.; Pet. Reply; PO Sur-reply. Moreover, our analysis does not rely on any particular construction of these terms and, so, we need not resolve this dispute.” slip op. at 10

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

    “2. “one or more measures derived from the group consistent of” Petitioner asserts limitations 1[g] and 1[g][i]–1[g][iv] recite an open Markush group listing alternatively useable members. Pet. 20–21 (citing Gillette Co. v. Energizer Holdings, Inc., 405 F.3d 1367, 1372 (Fed. Cir. 2005); Abbot Lab’ys v. Baxter Pharm. Prod., Inc., 334 F.3d 1274, 1281 (Fed. Cir. 2003) (explaining that the listing of specified alternatives within a claim is referred to as a Markush group or Markush grouping)); See Ex. 1001, 47:47–58. Patent Owner does not dispute Petitioner’s construction. See PO Resp; PO Sur-reply. As these terms are not in controversy, we need not opine on this construction.” slip op. at 10

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITANo construction neededNot reached

    “Petitioner’s and Patent Owner’s respective constructions overlap in their requirement that “cognate” users share similar past user actions and assessments or are defined by similar direct input by the user. See Pet. 18; PO Resp. 20–21; PO Sur-reply 10. Petitioner argues that Patent Owner’s construction “exclude[s] ‘groups’ from the claims” and further limits the scope of to users who share actions (Pet. Reply 8–9), but Patent Owner states that its proposed construction does not so limit the claims (PO Sur-reply 10). As such, there is no disagreement that “cognate” users share similar past user actions and assessments or are defined by similar direct input by the user. As there is no controversy, we need not, and do not, construe the meaning of “cognate.” However, Patent Owner’s requirement that “at least one other of the plurality of users” is specifically cognate to “the user” who was sent the content is plainly recited in the claim language itself. The claim recites a “relevance score of a piece of electronic content sent from a sender to a user” in the preamble and similarly again in limitation 1[g]. See Ex. 1001, 47:25–28 (emphasis added), 45:62–64. The limitation in question directly references the claimed “user” when reciting the cognate relationship: “identify at least one other of the plurality of users . . . that is cognate to the user.” Ex. 1001, 47:43–45 (emphasis added). As such, the claim language plainly supports Patent Owner’s requirement and Petitioner does not contest that requirement. See Pet. Reply 8. least one other of the plurality of users . . . that is cognate to the user” as requiring that the identified other user is cognate specifically to the user whose relevance score is being determined.” slip op. at 12

  Patent outcomesUS 7,716,217 unpatentable
  Claim construction§ 103 obviousnesscites KSR
  Patents in suitUS 7,716,217
• Assa Abloy AB / Assa Abloy Inc. et al. v. CPC Patent Technologies Pty, LtdNo claims unpatentable
  PTAB · May 27, 2026 · IPR2022-01093 · APJ Scott A Daniels · IPR · Remand

  Claims 13 and 14 were not shown unpatentable because the evidence did not establish that the received card information defines the memory location for the biometric signature.

  RulingsRemand decision

  • RemandOther

    “On appeal, the U.S. Court of Appeals for the Federal Circuit reversed our Original Decision and remanded the case for further proceedings. CPC Pat. Techs. Pty Ltd. v. ASSA Abloy AB, No. 2024-1492, 2025 WL 3134960, at *1 (Fed. Cir. Nov. 10, 2025), Paper 43. The Federal Circuit also noted that in light of the affirmance of our decision in another proceeding, IPR2022- 00600, challenging the same patent, the “errors the Board made in this appeal only extends to claims 3–18, which were not at issue in the other appeal.” Id. at *3 n 1. Therefore, in this proceeding, only challenged claims 13 and 14 remain. At the request of the parties, we permitted additional briefing addressing the issues on remand from the Federal Circuit. Paper 44. Petitioner filed an opening brief (Paper 51 (“Pet. Remand Br.”)), and Patent Owner filed an opening brief (Paper 52 (“PO Remand Br.”)). Both parties also filed responsive briefs. Paper 54 (“Pet. Responsive Br.”); Paper 55 (“PO Responsive Br.”). This is a Final Written Decision on Remand addressing the patentability of the remaining challenged claims 13 and 14. To prevail, Petitioner must prove unpatentability by a preponderance of the evidence. See 35 U.S.C. § 316(e); 37 C.F.R. § 42.1(d). This Final Written Decision on Remand is issued pursuant to 35 U.S.C. § 318(a) and 37 C.F.R. § 42.73.” slip op. at 3

  • BurdenNot shown unpatentable

    “offers nothing to suggest that its card information ‘tells you’ where to store the fingerprint data.” ASSA ABLOY AB, 2025 WL 3134960 at *3. Reversing our determinations as to Hsu, the Court found that the testimony of Petitioner’s declarant, Mr. Lipoff, “merely confirms the associative link between the card information and the biometric data. Still missing is any non-conclusory testimony that Hsu’s card information determines the memory location of the biometric data.” Id. at 8. Therefore, on remand, a central question is whether Petitioner has shown sufficiently that Tsukamura cures this deficiency. Petitioner has not done so. In the Petition, Petitioner relies on Tsukamura for teaching a specific location for storing fingerprint data. See Pet. 75 (stating that “Tsukamura’s index number specifies the physical memory location in the memory”). Petitioner argues that “[t]hus, Tsukamura discloses defining, dependent upon the “index number N index,” a memory location for storing a biometric signature (e.g., a fingerprint template), i.e., ‘a memory location is specified by the card information.’” Id. at 75–76 (citing Ex. 1006 ¶ 215). In support, Petitioner’s declarant, Mr. Lipoff, testifies that “[i]f the Tsukamura implementation were used for Sanford-Hsu database, each user/account number would specify a different entry (index number) in the database.” Ex. 1006 ¶ 394. Tsukamura’s index number N index does not teach or suggest much more than Hsu’s using “an account number or employee number, to access a stored there during an enrollment procedure.” Compare Ex. 1004, code (57), with Ex. 1005, 4:7–11. That is, both references arguably teach defining, i.e., setting or establishing, a certain location in a database for biometric data. For example, as described above, Tsukamura’s fingerprint template Temp is stored in flash ROM 35 at a defined index number N index in the database. Id. 4:7–11, 50–54. However, neither Petitioner, nor Mr. Lipoff, persuasively explain how or why Tsukamura’s fingerprint template Temp, stored at index number N index, is commensurate with “means for defining, dependent upon the received card information, a memory location in a local memory external to the card” as recited in claim limitation 13[C]. Ex. 1001, 14:3–5 (emphasis added).” slip op. at 22

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentable

    “Tsukamura’s index number N index does not teach or suggest much more than Hsu’s using “an account number or employee number, to access a stored there during an enrollment procedure.” Compare Ex. 1004, code (57), with Ex. 1005, 4:7–11. That is, both references arguably teach defining, i.e., setting or establishing, a certain location in a database for biometric data. For example, as described above, Tsukamura’s fingerprint template Temp is stored in flash ROM 35 at a defined index number N index in the database. Id. 4:7–11, 50–54. However, neither Petitioner, nor Mr. Lipoff, persuasively explain how or why Tsukamura’s fingerprint template Temp, stored at index number N index, is commensurate with “means for defining, dependent upon the received card information, a memory location in a local memory external to the card” as recited in claim limitation 13[C]. Ex. 1001, 14:3–5 (emphasis added).” slip op. at 22

  • Expert testimonyPetitioner expert discountedDecided for patent owner

    “Tsukamura’s index number specifies the physical memory location in the memory. Thus, Tsukamura discloses defining, dependent upon the “index number N index,” a memory location for storing a biometric signature (e.g., a fingerprint template), i.e., the memory location is specified by the index number, under the Second Construction. In my opinion, if the Tsukamura implementation were used for Sanford-Hsu database, each user/account number would specify a different entry (index number) in the database. Ex. 1006 ¶ 394. This is consistent with our understanding of Tsukamura, and we can agree that Tsukamura teaches defining—that is, setting or establishing—a location for storing the biometric signature at “index number N index.” See Ex. 1005, 4:7–11. However, considering the Federal Circuit’s decision, we determine such an associative link does not sufficiently explain how one of ordinary skill in the art would have understood Tsukamura’s IC” slip op. at 23

  Patent outcomesUS 8,620,039 not shown unpatentable
  Claim construction§ 103 obviousness
  Patents in suitUS 8,620,039
• Assa Abloy AB / Assa Abloy Inc. et al. v. CPC Patent Technologies Pty, LtdNo claims unpatentable
  PTAB · May 8, 2026 · IPR2022-01094 · APJ Scott A Daniels · IPR · Remand

  Claims 3–12 and 15–18 were not shown unpatentable because the asserted combinations did not establish that card information defined the memory location for storing the biometric signature.

  RulingsRemand decision

  • BurdenNot shown unpatentable

    “onset to show with particularity why the patent it challenges is unpatentable.” Harmonic Inc. v. Avid Tech., Inc., 815 F.3d 1356, 1363 (Fed. Cir. 2016) (citing 35 U.S.C. § 312(a)(3) as “requiring [inter partes review] petitions to identify ‘with particularity . . . the evidence that supports the grounds for the challenge to each claim’”); see also 37 C.F.R. § 42.104(b) (requiring a petition for inter partes review to identify how the challenged claim is to be construed and where each element of the claim is found in the prior art patents or printed publications relied upon). That burden never shifts to the patentee. Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015). Furthermore, Petitioner cannot satisfy its burden of proving obviousness by employing “mere conclusory statements.” In re Magnum Oil Tools Int’l, Ltd., 829 F.3d 1364, 1380 (Fed. Cir. 2016).” slip op. at 10

  • Skill levelOther

    “B. Level of Ordinary Skill in the Art Consistent with our Original Decision, a person of ordinary skill in the art at the time of the ’039 Patent would have had at least a bachelor’s degree in computer engineering, computer science, electrical engineering, or a related field, with at least one year of experience in the field of human-machine interfaces and device access security. Additional education or experience might substitute for the above requirements.” slip op. at 11

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

    “1. Limitation 3(da) The issues on remand revolve essentially around limitation 3(da): Limitation 3(da) – storing the inputted biometric signature in a memory at a memory location defined by the provided card information; Ex. 1001, 12:61–63. Considering limitation 3(da) in our Original Decision, we explained that during an enrollment process the claimed “biometric signature,” e.g., a fingerprint, is not yet stored in the memory, and no memory location or address has been “defined,” as in “set” or “established,” in the memory for storing the fingerprint, until card information is received. Once the card information and fingerprint are received during enrollment, the card information provides data that establishes where, i.e., at what memory location or address, the system will store the fingerprint data. Original Decision 16.” slip op. at 12

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentable

    “Tsukamura’s index number N index does not teach or suggest much more than Hsu’s using “an account number or employee number, to access a fingerprint database (44) and retrieve reference fingerprint data previously stored there during an enrollment procedure.” Compare Ex. 1004, code (57), with Ex. 1005, 4:7–11. That is, both references arguably teach defining, i.e., setting or establishing, a certain location in a database for biometric data. For example, as described above, Tsukamura’s fingerprint template Temp is Id. 4:7–11, 50–54. However, neither Petitioner, nor Mr. Lipoff, persuasively explain how or why Tsukamura’s fingerprint template Temp is set or established “at a memory location defined by the provided card information” as recited in claim limitation 3(da). Taking a close look at Petitioner’s testimonial evidence as to claim 3, we first note Mr. Lipoff testifies that Tsukamura’s index number specifies the physical memory location in the memory. Thus, Tsukamura discloses defining, dependent upon the “index number N index,” a memory location for storing a biometric signature (e.g., a fingerprint template), i.e., the memory location is specified by the index number, under the Second Construction. In my opinion, if the Tsukamura implementation were used for Sanford-Hsu database, each user/account number would specify a different entry (index number) in the database. Ex. 1006 ¶ 394. This is consistent with our understanding of Tsukamura, and we can agree that Tsukamura teaches defining—that is, setting or establishing—a location for storing the biometric signature at “index number N index.” See Ex. 1005, 4:7–11. But, concomitant with the Federal Circuit’s point, such an associative link does not sufficiently explain how one of ordinary skill in the art would have understood Tsukamura’s IC card information to define “as in ‘set’ or ‘establish[]’” a memory location, as our claim construction requires. See Section II.C.3.” slip op. at 22

  Patent outcomesUS 8,620,039 not shown unpatentable
  Claim construction§ 103 obviousness
  Patents in suitUS 8,620,039
• Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Maxell, Ltd.All claims unpatentable
  PTAB · Apr 27, 2026 · IPR2024-00906 · APJ Frederick C Laney · IPR · Final written decision

  Claims 1, 4–6, and 8–27 are unpatentable as obvious; Judge Hudalla dissented as to claim 15.

  RulingsFinal written decision

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication not establishedDecided for patent owner

    “reachable through intuitive navigation from the homepage using the descriptive titles to the reference, is sufficient to demonstrate the BT-Spec was publicly accessible. See M&K Holdings, Inc. v. Samsung Electronics Co., 985 F.3d 1376, 1381 (Fed. Cir. 2021) (“The law regarding public accessibility is not as restrictive as M&K suggests—a website’s landing page is not required to have search functionality. Instead, given the prominence of JCT-VC, the dispositive question is whether interested users of the JCT-VC website could have located Park and Zhou through reasonable diligence.”). The Bluetooth SIG website itself functioned as a well-known, organized repository that a skilled artisan would naturally consult when researching Bluetooth technology. See id. at 1382 (“The Board found that the documents in question on the meeting pages of the JCT-VC website were effectively indexed by subject matter in light of the title-search functionality and the fact that Park and Zhou featured descriptive titles. That finding supports the Board’s conclusion that Park and Zhou were publicly accessible.”).” slip op. at 39

  • ExcludeMotion to exclude, deniedDenied

    “IV. PATENT OWNER’S MOTION TO EXCLUDE The party moving to exclude evidence bears the burden of proof to” slip op. at 139

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

    “12. Conclusion Based on the complete record, we find a preponderance of the” slip op. at 115

  Patent outcomesUS 11,445,241 unpatentable
  § 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,445,241
• Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Maxell, Ltd.All claims unpatentable
  PTAB · Apr 27, 2026 · IPR2024-00907 · APJ Frederick C Laney · IPR · Final written decision

  Claims 1, 4, 5, 8–12, and 14–25 are unpatentable as obvious; the majority finds the asserted combinations persuasive despite 3GPP-Spec not qualifying as prior art.

  RulingsFinal written decision

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication not establishedNot shown unpatentable

    “accessibility. A document hosted on the official standards body website, reachable through intuitive navigation from the homepage using the descriptive titles to the reference, is sufficient to demonstrate the BT-Spec was publicly accessible. See M&K Holdings, Inc. v. Samsung Electronics Co., 985 F.3d 1376, 1381 (Fed. Cir. 2021) (“The law regarding public accessibility is not as restrictive as M&K suggests—a website’s landing page is not required to have search functionality. Instead, given the prominence of JCT-VC, the dispositive question is whether interested users of the JCT-VC website could have located Park and Zhou through reasonable diligence.”). The Bluetooth SIG website itself functioned as a well-known, organized repository that a skilled artisan would naturally consult when researching Bluetooth technology. See id. at 1382 (“The Board found that the documents in question on the meeting pages of the JCT-VC website were effectively indexed by subject matter in light of the title-search functionality and the fact that Park and Zhou featured descriptive titles. That finding supports the Board’s conclusion that Park and Zhou were publicly accessible.”).” slip op. at 40

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

    “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 approach.” Id. at 415. Whether a patent claiming the combination of prior 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 14

  • ExcludeMotion to exclude, deniedDenied

    “IV. PATENT OWNER’S MOTION TO EXCLUDE The party moving to exclude evidence bears the burden of proof to” slip op. at 158

  Patent outcomesUS 10,129,590 unpatentable
  § 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,129,590
• Apple Inc. v. DH International Ltd.All claims unpatentable
  PTAB · Apr 16, 2026 · IPR2025-00172 · APJ Brian P Murphy · IPR · Final written decision

  Claims 1–20 are unpatentable as obvious over Suga and Gorsuch; the Board denied Patent Owner’s motion to exclude.

  RulingsFinal written decision

  • ExcludeMotion to exclude, deniedDenied

    “Patent Owner also asserts prejudice for “not knowing” which Suga Exhibit “the Petitioner and Petitioner’s expert is relying on (see Exhibit 1021 and 1022),” without further explanation. Mot. Reply 6. Exhibit 1022 is a dictionary definition of “node.” How this relates to Patent Owner’s argument of prejudice is not explained. Id. at 5–6. The Board perceives no difficulty following Petitioner’s arguments and evidence, which cite Suga Exhibit 1005, including the testimony of Dr. Buehrer regarding the English language translation of Suga, which is identical in Exhibits 1005 and 1017. Patent Owner, moreover, opted not to depose Dr. Buehrer, did not file a deposition transcript of Dr. Buehrer in this proceeding, and does not allege any difference or substantive deficiency in the English language translation in Suga Exhibits 1005 and 1017, which are identical. We fail to see any prejudice to Patent Owner.” slip op. at 84

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

    “d. Conclusion for Claim 1 For the reasons given above, we determine the Petition establishes by” slip op. at 60

  Patent outcomesUS 9,022,294 unpatentable
  § 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,022,294
• 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
• Yealink (USA) Network Technology Co., Ltd. / Yealink Network Technology Co., Ltd. v. Barco N.V.All claims unpatentable
  PTAB · Apr 7, 2026 · IPR2024-01437 · APJ Meredith C Petravick · IPR · Final written decision

  Claims 1, 3, 9, 18, and 19 are unpatentable as obvious over Kaplan and Mardiks and over Maeda and Deforche.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner contends that a person having ordinary skill in the art would have had at least a Master’s Degree in Electrical Engineering and five years of work experience in computer science and embedded systems, or a Master’s Degree in Computer Science and five years of work experience in electrical and computer engineering and embedded systems. Additional educational experience could substitute for some of the work experience. Pet. 9 (citing Ex. 1002 ¶¶ 36–37). ordinary 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 ’237 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

    “standard that would be used in a civil action under 35 U.S.C. § 282(b). 37 C.F.R. § 42.100(b). In applying this standard, we generally give claim terms their ordinary and customary meaning as would be understood by a person of ordinary skill in the art at the time of the invention and in the context of the entire patent disclosure. See id.; Phillips v. AWH Corp., 415 F.3d 1303, 1312–14 (Fed. Cir. 2005) (en banc). Petitioner and Patent Owner propose constructions for a number of claim terms. Pet. 9–14; PO Resp. 8–10. Only those terms in controversy, however, need to be construed, and only to the extent necessary to resolve the controversy. Realtime Data LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019). We need not construe explicitly any claim term.” slip op. at 8

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “a) Whether Dr. Almeroth’s Testimony should Be Given Little Weight Patent Owner argues that we should give little weigh to the testimony of Dr. Almeroth because Dr. Almeroth’s testimony is allegedly inconsistent across the related inter partes reviews. PO Resp. 11–16; PO Sur-reply 21– 22. We have reviewed the disputed portions of Dr. Almeroth’s testimony and, when read in context, we are not persuaded that the testimony is inconsistent so as to be afforded little weight. As Petitioner points out (Pet. Reply 2), Patent Owner’s arguments do not properly account for the context in which the testimony was given in the related inter partes reviews.” slip op. at 16

  • Obviousness (§103) › Analogous artAnalogous artDecided for petitioner

    “Two separate tests define the scope of analogous prior art: (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 Deutschland Gmbh v. Mylan Pharms. Inc., 66 F.4th 1373, 1377 (Fed. Cir. 2023) (quoting In re Bigio, 381 F.3d 1320, 1325 (Fed. Cir. 2004) (citations omitted). We are persuaded by Petitioner that Mardiks meets at least the second test because both the ’237 patent and Mardiks “are directed to solving the same problem of using standard, pre-installed generic drivers, such as human interface device (HID) drivers, to access programs stored on peripheral devices.” Pet. Reply. 3–5; See Ex. 1001, 5:38–40; Ex. 1026 ¶¶ 3, 28. We, thus, are not persuaded by Patent Owner that Mardisk is non-analogous art. slip op. at 16

  Patent outcomesUS 11,403,237 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,403,237

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.