• Savant Technologies LLC D/B/A GE Lighting / Ledvance LLC et al. v. Feit Electric Company, Inc.All claims unpatentable
  PTAB · Aug 31, 2026 · IPR2025-00260 · APJ Kevin W Cherry · IPR · Final written decision

  The Board held all challenged original claims unpatentable as obvious and denied the contingent motion to amend substitute claims 30–49.

  RulingsFinal written decision

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

    “would have been motivated to combine the teachings of the prior art references to achieve the claimed invention, and that the skilled artisan would have had a reasonable expectation of success in doing so.’” Intelligent Bio-Sys., Inc. v. Illumina Cambridge Ltd., 821 F.3d 1359, 1367–68 (Fed. Cir. 2016); see KSR, 550 U.S. at 418. Further, an assertion of obviousness “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.” KSR, 550 U.S. at 418; In re NuVasive, Inc., 842 F.3d 1376, 1383 (Fed. Cir. 2016) (a finding of a motivation to combine “must be supported by a ‘reasoned explanation’”).” slip op. at 10

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

    “7. Summary As discussed above, we find that Patent Owner has failed to show a” slip op. at 35

  • PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend, deniedDenied

    “Motion to Amend meets the statutory and regulatory requirements set forth in 35 U.S.C. § 316(d) and 37 C.F.R. § 42.121 for claims 30 and 32–49. We further find that Patent Owner has not met the statutory and regulatory requirements for proposed claim 31. Accordingly, we address below whether any of the proposed substitute claims have been shown to be unpatentable.” slip op. at 86

  • Disclosure Requirements (§112) › Written description (Ariad)Written description inadequateDenied

  Patent outcomesUS 8,604,678 unpatentable
  § 103 obviousness§ 112 disclosurecites Phillips · Graham
  Patents in suitUS 8,604,678
• Savant Technologies LLC D/B/A GE Lighting / Ledvance LLC et al. v. Feit Electric Company, Inc.All claims unpatentable
  PTAB · Aug 31, 2026 · IPR2024-01357 · APJ Kevin W Cherry · IPR · Final written decision

  The Board held challenged claims 1–3, 6, 7, 9–14, 16–21, 25, 26, and 29 unpatentable as obvious, and granted the motion to amend for substitute claims 30–49.

  RulingsFinal written decision

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

    “would have been motivated to combine the teachings of the prior art references to achieve the claimed invention, and that the skilled artisan would have had a reasonable expectation of success in doing so.’” Intelligent Bio-Sys., Inc. v. Illumina Cambridge Ltd., 821 F.3d 1359, 1367–68 (Fed. Cir. 2016); see KSR, 550 U.S. at 418. Further, an assertion of obviousness “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.” KSR, 550 U.S. at 418; In re NuVasive, Inc., 842 F.3d 1376, 1383 (Fed. Cir. 2016) (a finding of a motivation to combine “must be supported by a ‘reasoned explanation’”).” slip op. at 10

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

    “7. Summary As discussed above, we find that Patent Owner has failed to show a” slip op. at 35

  • Expert testimonyPetitioner expert creditedDecided for petitioner
  • PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend, grantedGranted in part

    “5. Conclusion For the reasons set forth above, we determine that Patent Owner’s Motion to Amend meets the statutory and regulatory requirements set forth in 35 U.S.C. § 316(d) and 37 C.F.R. § 42.121 for claims 30 and 32–49. We further find that Patent Owner has not met the statutory and regulatory requirements for proposed claim 31. Accordingly, we address below whether any of the proposed substitute claims have been shown to be unpatentable.” slip op. at 86

  Patent outcomesUS 8,604,678 unpatentable
  § 103 obviousnesscites Phillips · Graham
  Patents in suitUS 8,604,678
• Savant Technologies LLC D/B/A GE Lighting / Ledvance LLC et al. v. Feit Electric Company, Inc.All claims unpatentable
  PTAB · Aug 31, 2026 · IPR2025-00260 · APJ Kevin W Cherry · IPR · Final written decision

  The Board held all challenged claims 1–3, 6, 7, 9–14, 16–21, 25, 26, and 29 unpatentable as obvious and granted the motion to amend for substitute claims 30–49.

  RulingsFinal written decision

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “E. Credibility of Dr. Doolittle Patent Owner argues that we should give no weight to Dr. Doolittle’s testimony because, “[o]n cross examination, Prof. Doolittle repeatedly contradicted himself, dodged questions, and tried to shoehorn new and nonresponsive opinions into his answers to Patent Owner’s questions.” PO Resp. 25. Patent Owner raises two major complaints about Dr. Doolittle. First, Patent Owner argues that he took inconsistent positions by asserting in these IPR proceedings that the claims were entitled to their plain and ordinary meaning, while in the parallel district court proceeding, asserting that certain claim terms were indefinite. Id. at 26–28. Second, Patent Owner argues that Dr. Doolittle “repeatedly dodged questions and tried to shoehorn new and nonresponsive opinions into his answers to Patent Owner’s questions,” and that “[d]uring cross examination Patent Owner was forced to object to Prof. Doolittle’s nonresponsive answers no less than eighteen times.” Id. at 28. We strongly disagree with Patent Owner’s characterization of Dr. Doolittle’s testimony. We have reviewed the entirety of both of Dr. Doolittle’s depositions. We are impressed with his forthrightness, candor, and good humor in the face of Patent Owner’s counsel’s aggressive questioning. Contrary to Patent Owner’s assertions, we find that his testimony was well-reasoned, forthright, honest, and entitled to significant weight. Dr. Doolittle explained the different claim construction positions We also strongly disagree that Dr. Doolittle’s answers were nonresponsive or “evasive” as Patent Owner argues. Patent Owner’s numerous attempts to “strike” portions of his testimony belie Dr. Doolittle’s efforts to honestly and in good faith respond to Patent Owner’s counsel’s questions. Ex. 2025, 22:10–23:15, 25:9–26:14, 30:14–22, 40:3-9, 58:12–59:1, 60:18–61:13, 65:1–10, 83:15–84:16, 92:15–95:20, 96:18–99:9, 102:22–106:16, 135:3–136:22. An answer is not “non-responsive” simply because it does not conform to the conclusion you want or undermines the logic underlying your questioning. Dr. Doolittle explained his answers and addressed the issues Patent Owner asked about. Accordingly, we decline Patent Owner’s invitation to give Dr. Doolittle’s testimony no weight. Instead, we assess Dr. Doolittle’s testimony on a case-by-case basis as discussed below.” slip op. at 21

  • Skill levelOther

    “B. Level of Ordinary Skill in the Art We consider the asserted ground of unpatentability in view of the understanding of a person of ordinary skill in the art (“POSITA” or “POSA”). In assessing the level of ordinary skill in the art, various factors may be considered, including the “type of problems encountered in the art; prior art solutions to those problems; rapidity with which innovations are made; sophistication of the technology; and educational level of active workers in the field.” In re GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995) (quoting Custom Accessories, Inc. v. Jeffrey-Allan Indus., Inc., 807 F.2d Relying on the declaration testimony of its expert, Dr. Doolittle, Petitioner contends that an ordinarily skilled artisan for the ’678 patent “would have had an undergraduate degree (i.e., B.S., B.S.E. or the equivalent) in electrical engineering, materials science, physics, or a similar discipline” and “would also have one to two years of experience in the field of LED packaging design.” Pet. 5–6. Petitioner additionally contends that “[m]ore education could substitute for experience, and vice versa.” Id. Petitioner further contends that “[t]his person would have been capable of understanding and applying the teachings of the ’678 patent and the prior-art references discussed herein,” and “[m]oreover, the prior art reflects the level of skill at the time of the claimed invention.” Id. (citing Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); Ex. 1102 ¶¶ 38–42). Patent Owner states that “solely for the purposes of this proceeding, Patent Owner and its technical expert employ the same level of skill in the art as Petitioners.” PO Resp. 24–25. Thus, we adopt Petitioner’s articulation of the level of ordinary skill in the art, which is consistent with the ’678 patent and the asserted prior art, and we apply it in our obviousness analysis below.” slip op. at 10

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

    “lower wavelength might offer, there were other drawbacks that a person of ordinary skill would have to balance. But “a given course of action often has simultaneous advantages and disadvantages, and this does not necessarily obviate motivation to combine.” Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006). Indeed, Petitioner has shown several references—including, Basin-2005, Shimizu, and Stokes—that made this tradeoff. Moreover, “[o]bviousness does not require absolute predictability of success. . . . [A]ll that is required is a reasonable expectation of success.” In re O’Farrell, 853 F.2d 894, 903–04 (Fed. Cir. 1988). We find that the prior art of record demonstrates that a person of ordinary skill in the art at the time of the invention would have such an expectation in making the combination of Basin-2007 and Basin-2005. Accordingly, we find that Petitioner has shown by a preponderance of the evidence that there would have been motivation to combine Basin-2007 and Basin-2005 with a reasonable expectation of success. 4. Summary We have reviewed Petitioner’s contentions regarding claims 1–3, 6, 9, 10, 16–21, and 25 (Pet. 19–53), and find that Petitioner has shown by a preponderance of the evidence that Basin-2007 and Basin-2005 teach the limitations of those claims, and that there would have been a motivation to combine the references in the manner suggested with a reasonable considerations does not outweigh the strong showing of obviousness. Accordingly, we find that Petitioner has shown by a preponderance of the evidence that claims 1–3, 6, 9, 10, 16–21, and 25 would have been obvious over Basin-2007 and Basin-2005.” slip op. at 41

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

    “1. Nexus In order for secondary considerations to be awarded “substantial” slip op. at 22

  Patent outcomesUS 8,604,678 unpatentable
  § 103 obviousness§ 112 disclosurecites Phillips · Graham
  Patents in suitUS 8,604,678
• Savant Technologies LLC D/B/A GE Lighting And Ledvance LLC / Savant Technologies LLC D/B/A GE Lighting, Elong International USA Inc., And Xiamen Longstar Lighting Co. Ltd v. Feit Electric Company, Inc.All claims unpatentable
  PTAB · Aug 31, 2026 · IPR2024-01357 · APJ Kevin W Cherry · IPR · Final written decision

  The Board held all challenged original claims unpatentable as obvious and granted the contingent motion to amend for substitute claims 30 and 32–49; substitute claim 31 was denied.

  RulingsFinal written decision

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “E. Credibility of Dr. Doolittle Patent Owner argues that we should give no weight to Dr. Doolittle’s testimony because, “[o]n cross examination, Prof. Doolittle repeatedly contradicted himself, dodged questions, and tried to shoehorn new and nonresponsive opinions into his answers to Patent Owner’s questions.” PO Resp. 25. Patent Owner raises two major complaints about Dr. Doolittle. First, Patent Owner argues that he took inconsistent positions by asserting in these IPR proceedings that the claims were entitled to their plain and ordinary meaning, while in the parallel district court proceeding, asserting that certain claim terms were indefinite. Id. at 26–28. Second, Patent Owner argues that Dr. Doolittle “repeatedly dodged questions and tried to shoehorn new and nonresponsive opinions into his answers to Patent Owner’s questions,” and that “[d]uring cross examination Patent Owner was forced to object to Prof. Doolittle’s nonresponsive answers no less than eighteen times.” Id. at 28. We strongly disagree with Patent Owner’s characterization of Dr. Doolittle’s testimony. We have reviewed the entirety of both of Dr. Doolittle’s depositions. We are impressed with his forthrightness, candor, and good humor in the face of Patent Owner’s counsel’s aggressive questioning. Contrary to Patent Owner’s assertions, we find that his testimony was well-reasoned, forthright, honest, and entitled to significant weight. Dr. Doolittle explained the different claim construction positions We also strongly disagree that Dr. Doolittle’s answers were nonresponsive or “evasive” as Patent Owner argues. Patent Owner’s numerous attempts to “strike” portions of his testimony belie Dr. Doolittle’s efforts to honestly and in good faith respond to Patent Owner’s counsel’s questions. Ex. 2025, 22:10–23:15, 25:9–26:14, 30:14–22, 40:3-9, 58:12–59:1, 60:18–61:13, 65:1–10, 83:15–84:16, 92:15–95:20, 96:18–99:9, 102:22–106:16, 135:3–136:22. An answer is not “non-responsive” simply because it does not conform to the conclusion you want or undermines the logic underlying your questioning. Dr. Doolittle explained his answers and addressed the issues Patent Owner asked about. Accordingly, we decline Patent Owner’s invitation to give Dr. Doolittle’s testimony no weight. Instead, we assess Dr. Doolittle’s testimony on a case-by-case basis as discussed below.” slip op. at 21

  • Skill levelOther

    “B. Level of Ordinary Skill in the Art We consider the asserted ground of unpatentability in view of the” slip op. at 10

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

    “lower wavelength might offer, there were other drawbacks that a person of ordinary skill would have to balance. But “a given course of action often has simultaneous advantages and disadvantages, and this does not necessarily obviate motivation to combine.” Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006). Indeed, Petitioner has shown several references—including, Basin-2005, Shimizu, and Stokes—that made this tradeoff. Moreover, “[o]bviousness does not require absolute predictability of success. . . . [A]ll that is required is a reasonable expectation of success.” In re O’Farrell, 853 F.2d 894, 903–04 (Fed. Cir. 1988). We find that the prior art of record demonstrates that a person of ordinary skill in the art at the time of the invention would have such an expectation in making the combination of Basin-2007 and Basin-2005. Accordingly, we find that Petitioner has shown by a preponderance of the evidence that there would have been motivation to combine Basin-2007 and Basin-2005 with a reasonable expectation of success. 4. Summary We have reviewed Petitioner’s contentions regarding claims 1–3, 6, 9, 10, 16–21, and 25 (Pet. 19–53), and find that Petitioner has shown by a preponderance of the evidence that Basin-2007 and Basin-2005 teach the limitations of those claims, and that there would have been a motivation to combine the references in the manner suggested with a reasonable considerations does not outweigh the strong showing of obviousness. Accordingly, we find that Petitioner has shown by a preponderance of the evidence that claims 1–3, 6, 9, 10, 16–21, and 25 would have been obvious over Basin-2007 and Basin-2005.” slip op. at 41

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

    “1. Nexus In order for secondary considerations to be awarded “substantial” slip op. at 22

  Patent outcomesUS 8,604,678 unpatentable
  § 103 obviousness§ 112 disclosurecites Phillips · Graham
  Patents in suitUS 8,604,678
• Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Manufacturing Resources International, Inc.All claims unpatentable
  PTAB · Aug 31, 2026 · IPR2023-00199 · APJ John A Hudalla · IPR · Final written decision

  Claims 1, 4, 7, and 8 are unpatentable as obvious over Na and Kim (claim 1) and Na and Hong (claims 4, 7, and 8); other grounds were not reached.

  RulingsFinal written decision

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

    “Manufacturing Resources International, Inc. (“Patent Owner” or “MRI”) filed a Preliminary Response. Paper 7 (“Prelim. Resp.”). Taking into account the arguments presented by Patent Owner in the preliminary record, we determined that the information presented in the Petition established that there was a reasonable likelihood that Petitioner would prevail with respect to its unpatentability challenges. Pursuant to 35 U.S.C. § 314, we instituted this proceeding on June 20, 2023, as to all challenged claims and all grounds of unpatentability presented in the Petition. Paper 9 (“Dec. on Inst.”).” slip op. at 2

  • ExcludeMotion to exclude, deniedDenied

    “Petitioner’s Motion to Strike Petitioner moves to strike Exhibits 2055, 2056, and 2058–2061 as being improper new evidence filed by Patent Owner with its Sur-reply in contravention of 37 C.F.R. § 42.23(b). Exclude Mot. 1–5. We have not relied on any of these exhibits in rendering this Decision. Accordingly, we dismiss as moot Petitioner’s Motion to Strike.” slip op. at 73

  • Skill levelSkill level board ownDecided for patent owner

    “record, we adopted the following definition of the level of ordinary skill in our Decision on Institution: [A] POSITA would have had a bachelor’s degree in a pertinent discipline, such as mechanical engineering, physics, applied physics, product design, or a related field, and would also have had 2–4 years of experience working with electronic displays, including the thermal management, product design issues, and failure modes, associated with such displays, or 5–7 years of experience in the field working with electronic displays and would have developed a similar understanding of thermal management, product design issues, and failure modes, associated with electronic displays. Dec. on Inst. 11. The parties’ positions have not changed since the time of institution, and we discern no reason to change the definition. Thus, we apply the same definition. We are satisfied that this definition comports with the level of skill necessary to understand and implement the teachings of the ’595 patent and the asserted prior art. Notwithstanding, we note that our analysis would not change if we adopted either party’s proposed definition in toto.” slip op. at 12

  • Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner

    “appear nowhere outside of the claims in the ’595 patent. This fact alone tends to undermine Patent Owner’s suggestion that the “posterior surface” must be distinct from the “rear side.” In addition, Patent Owner’s cited portions of the Specification merely refer to the “posterior surface” as being the surface opposite that on which the LEDs are mounted to which heat from the LEDs is transferred. See Ex. 1001, 4:53–55, 4:57–60. They are inconclusive as to whether the “posterior surface” must be distinct from the “rear side.” Further, Mr. Gershowitz’s testimony in support of a “distinct” construction is based on his interpretation of the words “on the” in claim 4’s recited “posterior surface on the rear side of the PCB.” Ex. 2006 ¶ 128. Specifically, he testifies that “[i]f the posterior surface was the rear side of the PCB, the claim would have said so.” Id. He does not cite any support in the Specification of the ’595 patent for his interpretation. See id. Given that his testimony amounts to speculation divorced from the context of the Specification, Mr. Gershowitz’s testimony is entitled to little weight. We also have considered Mr. Smith-Gillespie’s testimony in support of Petitioner’s contention that an ordinarily skilled artisan “would have understood that the rear outermost surface of the PCB is the recited ‘posterior surface.’” Pet. Reply 20 (citing Pet. 83; Ex. 1002 ¶ 243). He cites a passage in the Specification of the ’595 patent that states: “The PCB may comprise a metal core PCB and the posterior surface of the PCB may be metallic so that air within the constricted convection channel may cool the metallic posterior surface (and subsequently the backlight assembly) more easily and efficiently.” Ex. 1002 ¶ 243 (emphasis omitted) (quoting Ex. 1001, 4:60–65). We accord Mr. Smith-Gillespie’s testimony more weight than Mr. Gershowitz’s testimony given that Mr. Smith-Gillespie’s testimony is rooted in disclosures about metal core PCBs in the ’595 patent. It also gives some credence to the notion that the “posterior surface” and the “rear side” could be one and the same. Based on the record before us, we do not agree with Patent Owner that” slip op. at 19

  Patent outcomesUS 8,854,595 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,854,595
• Savant Technologies LLC D/B/A GE Lighting / Ledvance LLC et al. v. Feit Electric Company, Inc.All claims unpatentable
  PTAB · Aug 28, 2026 · IPR2024-01357 · APJ Kevin W Cherry · IPR · Final written decision

  Claims 1–3, 6, 7, 9, 10, 16–21, 25, 26, and 29 are unpatentable; substitute claims 30–49 were not reached.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art We consider the asserted ground of unpatentability in view of the” slip op. at 10

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “E. Credibility of Dr. Doolittle Patent Owner argues that we should give no weight to Dr. Doolittle’s testimony because, “[o]n cross examination, Prof. Doolittle repeatedly contradicted himself, dodged questions, and tried to shoehorn new and nonresponsive opinions into his answers to Patent Owner’s questions.” PO Resp. 25. Patent Owner raises two major complaints about Dr. Doolittle. First, Patent Owner argues that he took inconsistent positions by asserting in these IPR proceedings that the claims were entitled to their plain and ordinary meaning, while in the parallel district court proceeding, asserting that certain claim terms were indefinite. Id. at 26–28. Second, Patent Owner argues that Dr. Doolittle “repeatedly dodged questions and tried to shoehorn new and nonresponsive opinions into his answers to Patent Owner’s questions,” and that “[d]uring cross examination Patent Owner was forced to object to Prof. Doolittle’s nonresponsive answers no less than eighteen times.” Id. at 28. We strongly disagree with Patent Owner’s characterization of Dr. Doolittle’s testimony. We have reviewed the entirety of both of Dr. Doolittle’s depositions. We are impressed with his forthrightness, candor, and good humor in the face of Patent Owner’s counsel’s aggressive questioning. Contrary to Patent Owner’s assertions, we find that his testimony was well-reasoned, forthright, honest, and entitled to significant weight. Dr. Doolittle explained the different claim construction positions We also strongly disagree that Dr. Doolittle’s answers were nonresponsive or “evasive” as Patent Owner argues. Patent Owner’s numerous attempts to “strike” portions of his testimony belie Dr. Doolittle’s efforts to honestly and in good faith respond to Patent Owner’s counsel’s questions. Ex. 2025, 22:10–23:15, 25:9–26:14, 30:14–22, 40:3-9, 58:12–59:1, 60:18–61:13, 65:1–10, 83:15–84:16, 92:15–95:20, 96:18–99:9, 102:22–106:16, 135:3–136:22. An answer is not “non-responsive” simply because it does not conform to the conclusion you want or undermines the logic underlying your questioning. Dr. Doolittle explained his answers and addressed the issues Patent Owner asked about. Accordingly, we decline Patent Owner’s invitation to give Dr. Doolittle’s testimony no weight. Instead, we assess Dr. Doolittle’s testimony on a case-by-case basis as discussed below.” slip op. at 21

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

    “lower wavelength might offer, there were other drawbacks that a person of ordinary skill would have to balance. But “a given course of action often has simultaneous advantages and disadvantages, and this does not necessarily obviate motivation to combine.” Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006). Indeed, Petitioner has shown several references—including, Basin-2005, Shimizu, and Stokes—that made this tradeoff. Moreover, “[o]bviousness does not require absolute predictability of success. . . . [A]ll that is required is a reasonable expectation of success.” In re O’Farrell, 853 F.2d 894, 903–04 (Fed. Cir. 1988). We find that the prior art of record demonstrates that a person of ordinary skill in the art at the time of the invention would have such an expectation in making the combination of Basin-2007 and Basin-2005. Accordingly, we find that Petitioner has shown by a preponderance of the evidence that there would have been motivation to combine Basin-2007 and Basin-2005 with a reasonable expectation of success.” slip op. at 41

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

    “7. Summary As discussed above, we find that Patent Owner has failed to show a” slip op. at 35

  Patent outcomesUS 8,604,678 unpatentable
  § 103 obviousness§ 112 disclosurecites Phillips · Graham
  Patents in suitUS 8,604,678
• Genius Sports Ltd. v. Sportscastr Inc. D/B/A Panda InteractiveAll claims unpatentable
  PTAB · Aug 27, 2026 · IPR2024-01310 · APJ Stephen E Belisle · IPR · Remand

  On Director remand, the Board determined claims 1–15 unpatentable under § 103, including claims 1–11 over Ellis, Spivey, and Herzog.

  RulingsRemand decision

  • RemandOther

    “all Challenged Claims unpatentable and denying Petitioner’s Motion to Exclude. Paper 47 (“Original Final Decision”). Subsequently, Patent Owner filed a Request for Director Review and Petitioner filed an authorized Response thereto. Papers 48, 49. On July 29, 2026, the Director granted review, vacated-in-part the Original Final Decision, and remanded the case to the Board. Paper 50. In particular, the Director directed the Board “to consider Patent Owner’s arguments as to the webserver limitation in deciding whether Petitioner has established by a preponderance of the evidence that claims 1–11 are unpatentable under Petitioner’s Ground 1B.” Id. at 4. We do so in this Final Written Decision on Remand (“Remand Decision”). See infra § III.E (Ground 1B). For completeness, we repeat herein our analysis in the Original Final Decision for all other grounds.” slip op. at 2

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

    “C. Claim Construction We construe claims “using the same claim construction standard that would be used to construe the claim in a civil action under 35 U.S.C. 282(b), including construing the claim in accordance with the ordinary and customary meaning of such claim as understood by one of ordinary skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. § 42.100(b); see also Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). In this context, claim terms “are generally given their ordinary and customary meaning” as understood by a person of ordinary skill in the art in question at the time of the invention. Phillips, 415 F.3d at 1312–13; see CCS Fitness, Inc. v. Brunswick Corp., 288 F.3d 1359, 1366 (Fed. Cir. 2002) (There is “a ‘heavy presumption’ that a claim term carries its ordinary and customary meaning.”). “In determining the meaning of the disputed claim limitation, we look principally to the intrinsic evidence of record, examining the claim language itself, the written description, and the prosecution history, if in evidence.” DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469 F.3d 1005, 1014 (Fed. Cir. 2006) (citing Phillips, 415 F.3d at 1312–17). Extrinsic evidence is “less significant than the intrinsic record in determining ‘the legally operative meaning of claim language.’” Phillips, 415 F.3d at 1317. Petitioner contends that “[t]he claim terms of the ’218 [patent] should be given their plain and ordinary meaning” as understood by the relevant artisan. Pet. 6. Petitioner argues that the relevant artisan “would have understood a ‘socket’ to be a uniquely addressable communication endpoint on a server where first event information is provided to a [viewer client device] VCD.” Pet. 26 (citing Ex. 1001 ¶ 170). Petitioner argues that the relevant artisan also would have understood an “event socket,” in turn, to be “a socket where information about one sporting event is provided to VCDs.” Id. Beyond such proposed plain meanings for “socket” and “event” slip op. at 14

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

    “(6) Conclusion as to Objective Indicia of Non- Obviousness For the foregoing reasons, although we have considered Patent Owner’s evidence of objective indicia of nonobviousness, we accord it little weight, and find that it does not outweigh Petitioner’s strong countervailing evidence supporting a conclusion of obviousness.” slip op. at 53

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

    “engineer with substantial experience in Internet video streaming, Internet communication, and related protocols, including an understanding of relaytype and orchestrator-type webservers, would have considered the subject matter of claim 1 as a whole, including the webserver, to be obvious in light of the combined teachings of Ellis, Spivey, and Herzog. Based on the context discussed above, and for the reasons provided above, we determine that the answer is yes. See Fleming v. Cirrus Design Corp., 28 F.4th 1214, 1222 (Fed. Cir. 2022) (“That the proposed combination of [two references]—rather than one of the individual references—discloses the disputed claim limitations does not defeat the Board’s conclusion of obviousness. In this case, it is sufficient that [the relevant artisan] would have been motivated to combine the prior art in a way such that the combination discloses the claim limitations.”).” slip op. at 78

  Patent outcomesUS 11,039,218 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,039,218
• Apple Inc. / Amazon Web Services, Inc. v. Ziklag IP LLCAll claims unpatentable
  PTAB · Aug 26, 2026 · IPR2026-00047 · APJ Hung H Bui · IPR · Final written decision

  Claims 1–4, 6, 9–14, and 17 are unpatentable as obvious over Yurt and Logan; the Board denied Petitioner’s motion to strike.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Based on the record before us, we are unpersuaded that Patent Owner’s “proposed level of skill” is appropriate in this proceeding for reasons discussed below.” slip op. at 13

  • Expert testimonyPatent owner expert creditedDecided for patent owner

    “McCulloh’s qualifications are grounded upon Patent Owner’s “proposed level of skill” (which we rejected) that is “higher than Petitioner’s proposed level” (which we adopted for this proceeding) and focus on their level of skill in the late 1990s timeframe (time of the invention), but there is no time requirement on when an expert acquired the requisite level of skill in the art. Osseo Imaging, LLC v. Planmeca USA Inc., 116 F. 4th 1335, 1340–1341 (declining to add a timing requirement to the minimum qualifications necessary to offer expert testimony from the perspective of a person of ordinary skill in the art). “An expert need not have acquired that skill level prior to the time of the invention to be able to testify from the vantage point of a person of ordinary skill in the art. Rather, an expert can acquire the necessary skill level later and develop an understanding of what a person of ordinary skill knew at the time of the invention. In practice, the fact that the expert was not a person of ordinary skill at the time of the invention may well be used during cross examination to undermine the credibility of the expert.” Id. Under Petitioner’s proposed level of skill (which we adopted), Dr. McCulloh is indeed qualified to testify in this proceeding because he has a Ph.D. in Computer Science from Carnegie Mellon University and extensive experience, including “hands-on deployment and academic research in distributed systems operating under real-world constraints” (Ex. 2009, Ex. 2010). See Ex. 2010 (CV) (BSIE, MS Comp. Sci, PhD Comp. Sci, Lieutenant 1994-1999, 10th Mountain Division (“led the army’s first tactical deployment of a distributed computing system”)); Ex. 2009 ¶¶ 6–10. Although Dr. McCulloh’s declaration does not include any searching or analysis of patent literature including Yurt or Logan as part of his analysis of the “background” state of the art, as correctly recognized by Petitioner (Pet. Reply 7–8 (citing Ex. 1017, 74:18–75:14; Ex. 2009 ¶ 3)), we are persuaded that Dr. McCulloh is qualified to address Dr. Lippman’s portrayal of the architecture disclosed in the ’128 patent, as advanced by Patent Owner. Ex. 2009, ¶¶ 3, 5–34; Ex. 2010. Dr. McCulloh does not provide testimony to refute Petitioner’s obviousness analysis based on Yurt and Logan. See Ex. 2009. Mr. Johnson is only offered to refute Petitioner’s obviousness analysis based on Yurt and Logan. Ex. 2007 ¶¶ 3, 18, 29. Under Petitioner’s proposed level of skill (which we adopted), Mr. Johnson, who is a co-inventor of the ’128 patent, is qualified to testify in this proceeding, especially, when his declaration states that (1) he is a POSITA “with more than 30 years of experience building technology-driven media and contentdistribution systems” and (2) he “was actively involved in the development and deployment of digital music and video distribution technologies” since the mid-1990’s, including “real-time and near-real-time electronic delivery of media content.” Ex. 2007 ¶¶ 9–10, 14, 16. Certainly, “[t]he inventor himself may qualify as an expert and testify what his claims would mean in the relevant art.” Markman v. Westview Instruments, Inc., 52 F.3d 967, 991 (Fed. Cir. 1995).” slip op. at 17

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Plain and ordinary meaningNo construction needed

    “Plain Meaning of “Substantially Real Time” Instead, the plain meaning of “substantially real time” is readily apparent and understood by a person of skill (POSITA) in the art in the context of data distribution or transmission of the ’128 patent as referring to an acceptable time delay (i.e., “a fraction of real time”) between distribution center 18 and user device 12, via network 14, shown in Figures 1–2 of the ’128 patent and, as such, is consistent with the ‘128 patent’s specification and Dr. Lippman’s Declaration (Ex. 1003, ¶¶ 79, 126). Because the plain meaning of “substantially real time” as understood by a POSITA is readily apparent, there is no reason for the Board to consider Patent Owner’s clarification of “substantially real time” based solely on extrinsic evidence, i.e., counsel argument, Mr. Johnson’s declaration (Ex. 2007, ¶¶ 27, 29–30, 33, 39; Ex. 1018, 38:13–39:20) and Dr. McCulloh’s declaration (Ex. 2009, ¶ 19). For example, Patent Owner, relying upon Mr. Johnson’s testimony, clarifies the term “substantially real time” requires either (1) “playback while transmission is ongoing” (PO Resp. 30), or (2) “[a] coordinated system behavior in response to a user’s request” “in which a user request triggers coordinated operations, including locating content across distributed systems, routing that content, and initiating playback while transmission is ongoing” (PO Sur-Reply 4 (citing Ex. 1001, 2:67–3:2, 6:23–35)). However, Patent Owner’s shifting position regarding “substantially real time” is not commensurate with the plain reading of the term. Based on the plain meaning of “substantially real time,” we are persuaded by Petitioner that Yurt explicitly discloses transmitting data at least in “real time,” preferably “less than real time” or “a fraction of real time” for playback. Pet. Reply 9 (citing Ex.1005, code (57), 1:66–2:4, 4:68– 5:3 (teaching distributing “digital audio” in “less than real time” and in “a fraction of real time,” where the receiving system may “decompress in real time the requested material as it is distributed by transmission system 100”)).” slip op. at 36

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

    “teaches or renders obvious all limitations of claim 1, Petitioner also provides sufficient motivation or reasoning with a rational underpinning to combine Yurt and Logan. Specifically, Petitioner, relying on Dr. Lippman’s declaration (Ex. 1003, ¶¶ 62–73), asserts “a POSITA would have been motivated to combine Yurt with Logan for several reasons, discussed further below. Combining Logan’s usage log teachings with Yurt’s improved audio file accessibility (e.g., via popularity) to track additional user request information would have been obvious, beneficial, and predictable.” Pet. 19 (citing Ex. 1003, ¶¶ 62–72). According to Petitioner, because “Logan teaches implementation details for tracking user/usage data for billing purposes and adapting preferences ‘based on actual usage,’” “[a] POSITA would have thus been motivated to combine Yurt’s teachings (e.g., tracking information about requested items like item popularity) with Logan’s teachings (e.g., storing user data and usage information in response to user requests).” Id. at 19–20. “This would have been merely the use of a known technique (Logan’s tracking of user and usage data in response to user requests) to improve a similar method in the same way (Yurt’s tracking of information about user-requested items).” Id. at 20 (citing Ex. 1003, ¶¶ 67– 68). According to Petitioner, [T]he combination is straightforward: use Logan’s known technique for recording user data with Yurt’s existing item database teachings. See Ex. 1005, 12:28–57, 10:66–11:4; Ex. 1006, 5:33–42, 6:27–35, 8:49–58; Pet. 19–23. Since Yurt already teaches using its item database to track item popularity and request information, no modification to Yurt’s architecture is necessary. Logan merely confirms when and how to store the user information. Pet. 19–21. A POSITA would have found the combination obvious for all the reasons Dr. Lippman provided. See, e.g., Ex.1003, ¶¶ 71–72.” slip op. at 58

  Patent outcomesUS 6,182,128 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · Graham
  Patents in suitUS 6,182,128
• Apple Inc. / Amazon Web Services, Inc. v. Ziklag IP LLCAll claims unpatentable
  PTAB · Aug 26, 2026 · IPR2025-00700 · APJ Hung H Bui · IPR · Final written decision

  Claims 1–4, 6, 9–14, and 17 are unpatentable as obvious over Yurt and Logan; Petitioner’s motion to strike is denied.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Based on the record before us, we are unpersuaded that Patent Owner’s “proposed level of skill” is appropriate in this proceeding for reasons discussed below.” slip op. at 13

  • Expert testimonyPatent owner expert creditedDecided for patent owner

    “Under Petitioner’s proposed level of skill (which we adopted), Dr. McCulloh is indeed qualified to testify in this proceeding because he has a Ph.D. in Computer Science from Carnegie Mellon University and extensive experience, including “hands-on deployment and academic research in distributed systems operating under real-world constraints” (Ex. 2009, Ex. 2010). See Ex. 2010 (CV) (BSIE, MS Comp. Sci, PhD Comp. Sci, Lieutenant 1994-1999, 10th Mountain Division (“led the army’s first tactical deployment of a distributed computing system”)); Ex. 2009 ¶¶ 6–10. Although Dr. McCulloh’s declaration does not include any searching or analysis of patent literature including Yurt or Logan as part of his analysis of the “background” state of the art, as correctly recognized by Petitioner (Pet. Reply 7–8 (citing Ex. 1017, 74:18–75:14; Ex. 2009 ¶ 3)), we are persuaded that Dr. McCulloh is qualified to address Dr. Lippman’s portrayal of the architecture disclosed in the ’128 patent, as advanced by Patent Owner. Ex. 2009, ¶¶ 3, 5–34; Ex. 2010. Dr. McCulloh does not provide testimony to refute Petitioner’s obviousness analysis based on Yurt and Logan. See Ex. 2009. Mr. Johnson is only offered to refute Petitioner’s obviousness analysis based on Yurt and Logan. Ex. 2007 ¶¶ 3, 18, 29. Under Petitioner’s proposed level of skill (which we adopted), Mr. Johnson, who is a co-inventor of the ’128 patent, is qualified to testify in this proceeding, especially, when his declaration states that (1) he is a POSITA “with more than 30 years of experience building technology-driven media and contentdistribution systems” and (2) he “was actively involved in the development and deployment of digital music and video distribution technologies” since the mid-1990’s, including “real-time and near-real-time electronic delivery of media content.” Ex. 2007 ¶¶ 9–10, 14, 16. Certainly, “[t]he inventor himself may qualify as an expert and testify what his claims would mean in the relevant art.” Markman v. Westview Instruments, Inc., 52 F.3d 967, 991 (Fed. Cir. 1995). The fact that Johnson is a co-inventor is not in and of itself sufficient to discredit his testimony. “That an expert may have a bias or self-interest towards a party on whose behalf he or she is offering testimony, without more, generally does not require disqualifying the expert so long as the expert appears to be providing an objective analysis. Bias goes to the weight of the testimony, not necessarily its admissibility.” Apple, Inc. v. Motorola, Inc., 757 F. 3d 1286, 1321–22 (Fed. Cir. 2014). Nevertheless, the Board has broad discretion to assign weight to be accorded expert testimony. Yorkey v. Diab, 601 F.3d 1279, 1284 (Fed. Cir. 2010) (“[T]he Board was well within its discretion to give more credibility to [one expert over another] unless no” slip op. at 18

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Plain and ordinary meaningDecided for patent owner

    “Based on the record before us, we determine that neither Patent Owner’s proposed clarification nor an express construction of “substantially real time” is necessary for our proceeding. Plain Meaning of “Substantially Real Time” Instead, the plain meaning of “substantially real time” is readily apparent and understood by a person of skill (POSITA) in the art in the context of data distribution or transmission of the ’128 patent as referring to an acceptable time delay (i.e., “a fraction of real time”) between distribution center 18 and user device 12, via network 14, shown in Figures 1–2 of the ’128 patent and, as such, is consistent with the ‘128 patent’s specification and Dr. Lippman’s Declaration (Ex. 1003, ¶¶ 79, 126). Because the plain meaning of “substantially real time” as understood by a POSITA is readily apparent, there is no reason for the Board to consider Patent Owner’s clarification of “substantially real time” based solely on extrinsic evidence, i.e., counsel argument, Mr. Johnson’s declaration (Ex. 2007, ¶¶ 27, 29–30, 33, 39; Ex. 1018, 38:13–39:20) and Dr. McCulloh’s declaration (Ex. 2009, ¶ 19). For example, Patent Owner, relying upon Mr. Johnson’s testimony, clarifies the term “substantially real time” requires either (1) “playback while transmission is ongoing” (PO Resp. 30), or (2) “[a] coordinated system behavior in response to a user’s request” “in which a user request triggers coordinated operations, including locating content across distributed systems, routing that content, and initiating playback while transmission is ongoing” (PO Sur-Reply 4 (citing Ex. 1001, 2:67–3:2, 6:23–35)). However, Patent Owner’s shifting position regarding “substantially real time” is not commensurate with the plain reading of the term.” slip op. at 36

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

    “Conclusion as to Claim 1 Petitioner has shown that (1) Yurt and Logan teach or suggest all the limitation of claim 1 and (2) reasons sufficiently existed with a rational underpinning to support the combination of Yurt and Logan.” slip op. at 63

  Patent outcomesUS 6,182,128 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · Graham
  Patents in suitUS 6,182,128
• Apple Inc. v. Ferid AllaniAll claims unpatentable
  PTAB · Aug 25, 2026 · IPR2025-00857 · APJ Jeffrey S Smith · IPR · Final written decision

  Claims 1–27 are unpatentable: claims 24 and 26 over Rossmann and Himmel; claims 1–2, 4–6, 10–23, 25, and 27 over Rossmann, Himmel, King, and Adar; claims 3 and 7–9 over those references and Boyle.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “we consider the type of problems encountered in the art, the prior art solutions to those problems, the rapidity with which innovations are made, the sophistication of the technology, and the educational level of active workers in the field. See Custom Accessories, Inc. v. Jeffrey-Allan Industries, Inc., 807 F.2d 955, 962 (Fed. Cir. 1986); see Orthopedic Equip. Co. v. United States, 702 F.2d 1005, 1011 (Fed. Cir. 1983).” slip op. at 6

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

    “meaning of “icon” as claimed, including the dependent claims, the specification, the prosecution history, and the extrinsic evidence including expert testimony and dictionary definitions, we determine that the plain meaning of “icon” is readily apparent from the claims themselves. See Phillips, 415 F.3d at 1314 (“In some cases, the ordinary meaning of claim language as understood by a person of ordinary skill in the art may be readily apparent even to lay judges.”). We find that the plain meaning of “icon” as claimed encompasses at least “textual elements” because claim 20 recites “the icons comprise textual elements.” See id. (“Other claims of the patent in question, both asserted and unasserted, can also be valuable sources of enlightenment as to the meaning of a claim term.”). We highlight that the additional intrinsic evidence cited by the parties is consistent with the plain meaning. For example, Figures 1 and 2 of the specification show icons comprising textual elements. As another example, during prosecution of the ’058 patent, the Examiner found that the claimed icons were taught by textual hyperlinks. Ex. 1002, 586, 592. In order to overcome the Examiner’s rejection and obtain an allowance (id. at 641–50), applicant subsequently amended the claims to recite “specifically designed,” thus implicitly conceding to the Examiner’s interpretation of icon as encompassing textual hyperlinks. Id. at 625–640; see PO Resp. 43–44 (citing Ex. 1002, 626–27, 645–46) (acknowledging that the Examiner allowed the claims because applicant amended the claims to recite “specifically designed for containing a set of icons.”).” slip op. at 11

  • Claim Construction › Intrinsic evidence (Phillips canons) › Prosecution history disclaimer / disavowalTerm construed petitioner constructionDecided for petitioner

    “Requiring an element to be "specifically designed" for another element narrows the claim because it requires more than the first element being merely capable of being used with the second element. The term "configured to" is generally construed narrowly to mean "made to" and "designed to" rather than broadly to require merely "capable of". See In re Giannelli, 739 F. 3d 1375, 1379-80 (Fed. Cir. 2014) (the phrase "configured to" requires more than "mere capability." Rather, that term is synonymous with "made to" and "designed to."). However, rather than use "configured to", in order to avoid any confusion as to the narrower scope of the claims as amended, Applicant herein directly and explicitly requires "designed to." In re Giannelli at 1379-80 (Fed. Cir. 2014) (reversing an obviousness rejection because (1) the claims were properly construed narrowly to mean "designed to" and not broadly to encompass merely "capable of", and (2) the USPTO had not explained the motivation for modifying the prior art to meet the "design to" requirement) See also MPEP 2111.04, citing to In re Giannelli, for the proposition that a claim can be narrowed to require that it be "designed and constructed to be used" in a specific manner (as a rowing machine in the case of In re Giannelli). Logan has not been specifically designed and constructed in the required manner, so it does not cure all deficiencies of the primary reference Iki (which lacks any tree menu structure). Logan describes only "remote web" pages 90, 95 that are merely pages retrieved from Web browsing and stored in a web computer 25. Iki as modified by Logan would result on in a tree menu structure wherein not all levels of the tree included the required selection pages specifically designed for containing the claimed set of icons. Ex. 1002, 626–27 (emphasis omitted).” slip op. at 14

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

    “Petitioner contends that a person of ordinary skill in the art would have modified Rossmann to include several advantages expressly taught by Himmel: Himmel’s consumer hot list bookmark set for the benefits of providing a user with a consistent user interface when accessing a website; to simplify navigation for the user by providing an additional navigation aid; to provide more immediate access to commonly used web actions; to reduce the network traffic required to navigate through webpages to arrive at a particular web function; and to reduce usage charges and data usage. Pet. 22–23 (citing Ex. 1003 ¶¶ 94–99; Ex. 1004, 2:38–56, 12:24–34, 14:35–44; Ex. 1005, 18:63–65, 20:11–16). Petitioner contends that modifying Rossmann’s Figures 4A through 4G to include Himmel’s consumer hot list bookmark set yields each selection page including both selection icons for navigating to other local pages along with direct access icons such as on sale today to directly navigate to a predetermined web site to perform a common web action. Id. at 23–25 (citing Ex. 1003 ¶¶ 96–100; Ex. 1004, Figs. 4D–F). Petitioner contends that the selection page of Rossmann as modified by the bookmark set of Himmel teaches a first locally stored page specifically designed to include a direct access icon because the selection page is “used to include” a direct access icon, such as on sale today, and that during use, this selection page is programmed to display the set of direct access icons for selection by the user. Pet. 25 (citing Ex. 1003 ¶¶ 96–100); see id. at 21–24. Petitioner contends that a person of ordinary skill in the art would have had a reasonable expectation of success because technology for bookmarking websites and web actions was known at the time of invention, modifying Rossmann to utilize known bookmark manager software would have been straight forward, Rossmann already includes hardware and programming instructions to access a web server, and Himmel teaches that known prior art methods utilized both selection and direct access icons on a single page. Id. at 25–26 (citing Ex. 1003 ¶¶ 101–103; Ex. 1004, 2:38–41, 14:21–44; Ex. 1005, Fig. 6A, 21:27–34).” slip op. at 19

  Patent outcomesUS 10,943,058 unpatentable
  Claim construction§ 103 obviousnesscites Phillips
  Patents in suitUS 10,943,058

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.