- Samsara Inc. v. Motive Technologies, Inc.No claims unpatentablePTAB · Jul 29, 2026 · IPR2025-00574 · APJ Daniel J Galligan · IPR · Final written decision
Claims 1–7 were not shown unpatentable because the asserted combinations did not establish the claimed video overlay and transmission for manual review.
RulingsFinal written decision- Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentableNot shown unpatentable
“We agree with Patent Owner that Petitioner’s contentions in this ground do not cure the issues for limitations 1D and 1E. Petitioner’s contentions in this ground involve combining Khan and Ali’s teachings of identifying a horizon line and lane lines with Choe. For example, Petitioner argues that “[u]sing predictive models for Choe’s lane and horizon prediction would have combined known elements according to known methods to yield predictable results” and that “[i]mplementing these known mathematical models in Choe’s calibration system, according to their known functions, would have yielded predictable results.” Pet. 39. Petitioner further argues that “[u]sing predictive models for Choe’s lane and horizon prediction would have used a known technique (predictive models) to improve similar devices in the same way” and that “[u]sing predictive models for Choe’s lane and horizon prediction would have also applied a known technique (predictive models) to a known device (a manual annotator device) ready for improvement.” Pet. 40. Petitioner’s proposed combination, therefore, still relies on Choe’s teachings of transmitting an overlaid image to an annotator device. We note that Petitioner asserts that, “[o]nce Khan in view of Ali identifies the horizon and lane lines, it overlays the horizon line and/or lane lines on the video, as shown in the screenshots below.” Pet. 41–42. Although Petitioner mentions Khan and Ali’s teachings with respect to video here, Petitioner does not adequately explain how the teaching of an overlaid video would be combined with Choe’s single image annotator teachings. As discussed above, Choe discloses transmitting a single overlaid image to the annotator” slip op. at 23
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable
“Thus, Petitioner has not provided sufficient evidence and argument to explain how the additional teachings of Khan and Ali teach limitations 1D and 1E in combination with Choe. Petitioner, therefore, has not demonstrated unpatentability of claims 1–5 by a preponderance of the evidence. F. Obviousness over Choe and Workman (Claims 1–4) Petitioner asserts that claims 1–4 would have been obvious over the combined teachings of Choe and Workman. Pet. 47–52; Pet. Reply 26–30. Petitioner asserts that, “if [Patent Owner] alleges that Choe does not explicitly disclose which predictive models it uses or whether it uses predictive models to identify the horizon line, a [person of ordinary skill in the art] would have searched for references that use predictive models and how such models were used,” which “would have led to Workman, which discloses predictive models to identify the horizon line.” Pet. 47. According to Petitioner, “[u]sing Workman’s predictive model to identify the horizon line would also have merely been combining known elements ([convolutional neural networks (CNNs)] and annotation for camera calibration) according to known methods to yield predictable results and used known techniques (CNNs) to improve similar devices in the same way.” Pet. 48–49. Thus, Petitioner relies on Workman to teach a predictive model to identify a horizon line. See Pet. 47–49. Choe with respect to limitations 1D and 1E. Indeed, Workman involves horizon line estimation in single images. See Ex. 1011, 10 (§ 5) (“We introduced Horizon Lines in the Wild (HLW), a new dataset for single image horizon line estimation, to address the limitations of existing horizon line detection datasets.”). Petitioner, therefore, has not demonstrated unpatentability of claims 1–4 by a preponderance of the evidence.” slip op. at 24
- Skill levelSkill level patent owner adoptedDecided for patent owner
“Patent Owner criticizes Petitioner’s proposed level of ordinary skill for not requiring “any training or experience in ‘automotive systems,’ precisely what the ’580 [p]atent relates to.” PO Resp. 7. According to Patent Owner, a person of ordinary skill in the art would have had “a training and/or experience in design of software for camera/sensor systems in the automotive industry.” PO Resp. 8–9 (citing Ex. 2003 ¶ 35).” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“C. Claim Construction We need not construe expressly any claim terms to decide the issues before us. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 6
Patent outcomesUS 11,875,580 not shown unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,875,580 - PTAB · Dec 10, 2025 · IPR2025-01069 · APJ Daniel J Galligan · IPR · Institution
The Board instituted IPR on claims 1–14 and all asserted grounds, finding a reasonable likelihood of prevailing based on Bharadwaj alone and Bharadwaj with Yu.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“institute review. Paper 11. The standard for instituting an inter partes review is set forth in 35 U.S.C. § 314(a), which provides that an inter partes review may not be instituted unless the information presented in the Petition and the Preliminary Response shows “there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons explained below, we institute an inter partes review of all challenged claims on all grounds raised in the Petition.” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“To the extent Patent Owner contends that a person of ordinary skill in the art need not be defined as of the critical date, we disagree. Under Section 103, we must determine “if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains” (emphasis added). “Obviousness is determined from the vantage point of a hypothetical person having ordinary skill in the art to which the patent pertains.” In re Rouffet, 149 F.3d 1350, 1357 (Fed. Cir. 1998). Thus, we define the hypothetical person of ordinary skill in the art as of a time before the effective filing date. To the extent Patent Owner’s argument is that, to testify from the perspective of a person of ordinary skill in the art, one need not have been a person of ordinary skill in the art as of the critical date, we agree. Although one must at least possess ordinary skill in the art to testify from the perspective of a person of ordinary skill, [a]n 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. Osseo Imaging, LLC v. Planmeca USA Inc., 116 F.4th 1335, 1341 (Fed. Cir. 2024). the uncontested assessment offered by Petitioner, which appears consistent with the ’077 patent and the asserted prior art, except that we delete the qualifier “at least” to eliminate vagueness as to the amount of experience.” slip op. at 6
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“C. Claim Construction The parties agree that no claim terms require express construction. Pet. 10; Prelim. Resp. 2–4. Patent Owner, however, notes that, in related district court litigation, Petitioner has asserted that some claims terms are indefinite. Patent Owner argues that the Petition should be denied because Petitioner has taken inconsistent claim construction positions between the district court and the Board. Paper 14 at 1–3 (citing Tesla, Inc. v. Intellectual Ventures II LLC, IPR2025-00340, Paper 18 at 4 (PTAB Nov. 5, 2025) (informative); Revvo Techs., Inc. v. Cerebrum Sensor Techs., Inc., IPR2025-00632, Paper 20 at 4–5 (PTAB Nov. 3, 2025) (precedential)). Petitioner responds that, in the related district court litigation, the parties have narrowed the claim construction disputes and that Petitioner accords the plain and ordinary meaning to claim terms and no longer asserts that any claim term of the ’077 patent is indefinite. Paper 15 (citing, inter alia, Ex. 1126 (Defendants’ Responsive Claim Construction Brief)). The evidence supports Petitioner’s position because, in the related district court litigation, the defendants agree with the plaintiff (Patent Owner) that certain phrases in the ’077 patent claims should be given their “[p]lain and ordinary meaning” and are “not indefinite.” Ex. 1126, 6 (native page 1). Thus, the record does not show inconsistent claim construction positions that warrant denial under PTAB precedent. See Revvo, Paper 20 at 5 (addressing a situation in which a petitioner advances “different claim construction positions” in district court and at the PTAB). See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 7
- Novelty / Anticipation (§102) › Prior-art status of a reference › Patents / published applications (effective date, provisional support)Reference is prior artDecided for petitioner
“We agree with Patent Owner that Bharadwaj includes subject matter that is not in Bharadwaj-Prov59, namely the change from adding the value Resp. 20; Ex. 1007 ¶ 51 (adding m); Ex. 1006 ¶ 50 (subtracting m); Prelim. Resp. 20. Petitioner, however, points out this change in the Petition and acknowledges that it is after the identified critical date of August 20, 2015. See Pet. 28. Thus, we do not understand Petitioner to be relying on Bharadwaj’s disclosure of subtracting m to determine length, as disclosed in the publication of the non-provisional application, as a prior art disclosure. We understand Petitioner to be relying on disclosures in Bharadwaj-Prov059 for prior art teachings for its obviousness contentions. Patent Owner does not appear to dispute that Bharadwaj-Prov59’s disclosures are prior art, arguing instead that it is improper to rely “on matters in Bharadwaj beyond ‘incorporation by reference’ of the Bharadwaj-Prov59.” See Prelim. Resp. 20–21. On this record, we determine that Bharadwaj-Prov59’s disclosures are prior art as of its June 2, 2015, filing date by virtue of its incorporation by reference into Bharadwaj, a published US patent application. Ex. 1006 ¶ 1; see Pet. 12–13.” slip op. at 8
Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,313,077 - Kia Corp. / Toyota Motor Corp. v. Emerging Automotive LLCAll claims unpatentablePTAB · Dec 9, 2025 · IPR2024-00981 · APJ Georgianna W Braden · IPR · Final written decision
Claims 1–20 are unpatentable over the Kleve-based grounds; the Board found the Zaid-based grounds did not render their challenged claims unpatentable.
RulingsFinal written decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Pet. 2. Patent Owner filed a Preliminary Response (Paper 7, “Prelim. Resp.”). Petitioner filed an authorized Reply to Patent Owner’s Preliminary Response (Paper 8, “Prelim. Reply”), and Patent Owner filed an authorized Sur-reply to Petitioner’s Reply (Paper 9, “Prelim. Sur-reply”). Trial was instituted on the asserted grounds of unpatentability. Paper 10 (“Inst. Dec.”), 56.” slip op. at 3
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner contends express claim construction is unnecessary and states that all terms should be given their plain and ordinary meaning. Pet. 8. Patent Owner does not address claim construction in its Response. Construction is needed only for those terms “that are in controversy, and only to the extent necessary to resolve the controversy.” See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)). There are no claim terms in controversy that need be construed for our analysis.” slip op. at 10
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Here, Petitioner asserts a person of ordinary skill in the art would have “had at least a four-year undergraduate degree in electrical engineering, automotive engineering, or [a] closely related field and [at] least two years of experience in the field of access control systems, vehicle electronics, and/or cryptography.” Pet. 2 (citing Ex. 1003 ¶¶ 79–82). Dr. Almeroth supports Petitioner’s position and further testifies that “[a]dditional education could substitute for professional experience and vice versa.” Ex. 1003 ¶ 79. Patent Owner does not assert a different level of skill in the art at the time of the alleged invention and appears to apply Petitioner’s proposed level of skill. See PO Resp. Patent Owner’s declarant, Dr. Malek, explicitly adopts Petitioner’s level of skill in the art but states that his opinions would be applicable under any reasonable definition for an ordinarily skilled artisan at the critical time. See Ex. 2001 ¶ 37. For the purposes of this Decision, we too adopt Petitioner’s level of ordinary skill in the art because it appears consistent with the problems addressed in the ’188 patent and the prior art of record.” slip op. at 11
- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
“Additionally, we credit the testimony of Dr. Almeroth, who opines that Kleve discloses that certain restrictions are sent with the request to generate a virtual key. Ex. 1003 ¶¶ 118–123. Specifically, Dr. Almeroth testifies that Kleve discloses that the virtual key “enable[s] the keyless drive system for the appropriate Temporary User during a given rental period.” Id. According to Dr. Almeroth, this “indicates that rental agreement restrictions were sent with the request so that the virtual key could be associated with said restrictions.” Id. (citing Ex. 1004 ¶¶ 39, 68 (“Once the rental period has expired the virtual key may be reset and cleared from the VCS.”)). Dr. Almeroth further testifies that the virtual key in Kleve is always generated after the rental agreement. Id. (citing Ex. 1004 ¶¶ 39 (“[O]nce the Temporary User selects the vehicle, pays the appropriate amount and signs a consent agreement, th[e]n the system may generate a virtual key to distribute to the Temporary User and VCS.”), 68). We do not agree with Patent Owner’s argument that Dr. Almeroth’s declaration testimony contradicts Kleve. See PO Resp. 27–29. Rather, as discussed previously, we find that Kleve’s vehicle owner can set a restriction, such as the rental start period, prior to step 214 in Kleve’s Figure 2 and that such restrictions can be associated with the e-key. We also do not agree with Patent Owner’s argument that (1) Dr. Almeroth’s declaration testimony contradicts his deposition testimony or that (2) Dr. Almeroth “admitted his testimony was wrong.” See PO Sur-Reply 7 (citing Ex. 2030, 27:5–10, 27:21–28:1). In a particular embodiment to which Dr. Almeroth was citing, he noted that the e-key is always generated after the rental agreement. See Ex. 2030, 26:14–20. Then the following exchange occurs: Q. So you use typically and always. So always does not refer to all of the embodiments of Kleve, is that fair? A. I think a person of skill in the art could read Kleve and understand that there are probably multiple ways in which the flow of actions among the parties could occur. And I think thinking about a real world scenario, in most cases you have an agreement before you would generate an eKey, but maybe, maybe not. I don’t -- I don't know that the real world is necessarily cut and dry. So reading -- a person reading Kleve would understand it’s describing embodiments where it’s always the case. That might be a pretty common scenario, but I don't know that it would necessarily be a hard and fast rule in every embodiment or in the understanding a person of skill in the art would have. Id. at 28:3–20. There is nothing in the deposition testimony by Dr. Almeroth that appears inconsistent with his declaration testimony nor does there appear to be the kind of admission touted by Patent Owner. Instead, it is Dr. Malek who takes an overly narrow view of Kleve that appears inconsistent with Kleve’s disclosure when read as a whole. See, e.g., Ex. 2001 ¶¶ 56–57. Therefore, we do not credit or agree with Dr. Malek’s testimony that Kleve teaches away from the concept of a virtual key created with the agreed-upon rental period as a restriction. See id. ¶ 57.” slip op. at 31
Patent outcomesUS 9,365,188 unpatentableClaim construction§ 103 obviousnesscites Phillips · GrahamPatents in suitUS 9,365,188 - Good Sportsman Marketing, LLC v. Hangzhou ZH Tech Co., Ltd.All claims unpatentablePTAB · Nov 20, 2025 · PGR2024-00034 · APJ Annette R Reimers · PGR · Final written decision
Claims 1–19 are unpatentable: claims 1–19 as obvious over Unger and Smith, claim 18 also as obvious over Unger, Smith, and Hakansson, and claims 3–6, 8, 9, and 16 as indefinite.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“We note that the identification of a Ph.D. as an example of “more formal education” creates a vast range of education relative to a bachelor’s degree. Thus, we treat the identification of a Ph.D. just as it is—an example—and not a requirement. In this case, “more formal education” can be satisfied by a level of education less than a Ph.D (but greater than a bachelor’s degree). Based on our review of the record before us, we determine that Petitioner’s stated level of ordinary skill in the art is reasonable because it appears consistent with the evidence of record, including the asserted prior art. Accordingly, we adopt Petitioner’s definition, limited as discussed above, for the purposes of this Decision.” slip op. at 15
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner contends that it “does not believe any terms need to be construed to resolve the prior art issues presented in this Petition.” Pet. 20 (citing Ex. 1002 ¶ 89). any claim language because doing so would have no effect on our analyses below of Petitioner’s asserted grounds and will not assist in resolving the present controversy between the parties. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’”) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)).” slip op. at 15
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“Petitioner argues that one of ordinary skill in the art would have found the proposed modification obvious for several reasons. Pet. 30. For instance, Petitioner argues that “Unger contains an express teaching, suggestion and/or motivation to incorporate an element such as Smith’s torsional spring into the lower and/or upper mount assemblies 308, 312 to facilitate attachment and detachment.” Id. Namely, Petitioner points to Unger’s disclosure that device mounts 308, 312 may be flexible or resilient so that device mounts 308, 312 may be bent to engage a portion of hearing protection device 108 and are then allowed to return to a normal state to secure communication device 104 to hearing protection device 108. Id. at 30–31 (quoting Ex. 1004, 6:20–37). Petitioner adds that one of ordinary skill in the art would have understood this disclosure “to teach that mount arms 308, 312 could be removable from housing 304 (e.g., as mount arm 312 is in Figure 6) and/or they could be designed to be ‘flexible’ or ‘resilient’ such that they can be manipulated,” and “that ‘resilient’ is defined as ‘bouncing or springing back into shape, position, etc. after being stretched, bent, or, esp., compressed.’” Id. at 31 (citing Ex. 1002 ¶ 117). Thus, according to Petitioner, this disclosure of Unger suggests using a torsion spring. Id. In addition, Petitioner asserts that one of ordinary skill in the art would have understood Unger’s disclosure to “suggest the use of a torsion designed to impart this functionality.” Pet. 30 (citing Ex. 1002 ¶ 118). Petitioner also asserts that one of ordinary skill in the art would have “understood that there were a limited number of ways to impart the referenced resilient or flexible ‘manipulation,’” and “would have been motivated to look to various known solutions to impart the suggested functionality, including the torsional spring mechanism of Smith that is used in a similar hearing protection device application for a similar purpose as Unger’s mounting arms (to apply a clamping force).” Id. at 32 (citing Ex. 1002 ¶¶ 120–121). Other reasons for combining the references set forth by Petitioner are the proposed modification: (1) “would have involved applying a known technique to a known device ready for improvement to yield predictable results” (Pet. 39–49 (citing Intel Corp. v. PACT XPP Schweiz AG, 61 F.4th 1373, 1380 (Fed. Cir. 2023); Ex. 1002 ¶ 131)), (2) would have constituted “combining prior art elements using known methods to achieve predictable results” (id. at 40 (citing KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007); Ex. 1002 ¶ 133)); and (3) would have been “the simple substitution of one known element (i.e., Smith’s torsion spring mechanism) into another (i.e., the connection point of Unger’s lower mount arm 308 and housing 304)” (id. at 40–41 (citing Apple Inc. v. Samsung Elecs. Co., 839 F.3d 1034, 1077 (Fed. Cir. 2016); Ex. 1002 ¶ 135)). Petitioner argues that one of ordinary skill in the art would have had a” slip op. at 22
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“i) Conclusion For the above reasons, we find, based on the record before us, that Petitioner establishes by a preponderance of the evidence that claim 1 would have been obvious over the combination of Unger and Smith. Patent Owner does not contend that any limitations in claim 1 are absent in the combination of Unger and Smith, or that claim 1 would not have been obvious over the combination of Unger and Smith, and therefore, has waived such arguments.8” slip op. at 28
Patent outcomesUS 11,736,855 unpatentableClaim construction§ 103 obviousness§ 112 disclosurecites KSR · Graham · NautilusPatents in suitUS 11,736,855 - PTAB · Nov 7, 2025 · IPR2025-01044 · APJ Daniel J Galligan · IPR · Institution
The Board instituted IPR of claims 1–10 on all asserted grounds, finding a reasonable likelihood that Samsung would prevail on at least claim 1 under §103.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“institute review. Paper 11. The standard for instituting an inter partes review is set forth in 35 U.S.C. § 314(a), which provides that an inter partes review may not be instituted unless the information presented in the Petition and the Preliminary Response shows “there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons explained below, we institute an inter partes review of all challenged claims on all grounds raised in the Petition.” slip op. at 2
- Skill levelSkill level board ownDecided for petitioner
“had a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and at least 3 years of experience in the research, design or development of wireless communication devices, systems, and/or networks, or the equivalent, as of the Critical Date,” which we understand Petitioner identifies as September 7, 2016. Pet. 2, 4 (citing Ex. 1003 ¶¶ 26–28). Petitioner also contends that “[i]ncreased educational experience can make up for less work experience, and vice versa.” Pet. 4. Patent Owner does not object to Petitioner’s definition at this stage. Prelim. Resp. 11. To the extent necessary, and for purposes of this Decision, we accept the uncontested assessment offered by Petitioner, which appears consistent with the ’879 patent and the asserted prior art, except that we delete the qualifier “at least” to eliminate vagueness as to the amount of experience.” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“C. Claim Construction The parties agree that no claim terms require express construction. Pet. 4; Prelim. Resp. 11. On this record, we determine that no terms need express construction. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve” slip op. at 5
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundOther
Claim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,516,879 - PTAB · Nov 7, 2025 · IPR2025-01043 · APJ Daniel J Galligan · IPR · Institution
The Board instituted IPR of claims 1–10 on all petition grounds, finding a reasonable likelihood that Samsung would prevail on at least claim 1 as obvious over Zhou, Cherian, and Kim.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“institute review. Paper 11. The standard for instituting an inter partes review is set forth in 35 U.S.C. § 314(a), which provides that an inter partes review may not be instituted unless the information presented in the Petition and the Preliminary Response shows “there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons explained below, we institute an inter partes review of all challenged claims on all grounds raised in the Petition.” slip op. at 2
- Skill levelSkill level board ownOther
“had a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and at least 3 years of experience in the research, design or development of wireless communication devices, systems, and/or networks, or the equivalent, as of the Critical Date,” which we understand Petitioner identifies as September 7, 2016. Pet. 2, 4 (citing Ex. 1003 ¶¶ 26–28). Petitioner also contends that “[i]ncreased educational experience can make up for less work experience, and vice versa.” Pet. 4. Patent Owner does not object to Petitioner’s definition at this stage. Prelim. Resp. 11. To the extent necessary, and for purposes of this Decision, we accept the uncontested assessment offered by Petitioner, which appears consistent with the ’035 patent and the asserted prior art, except that we delete the qualifier “at least” to eliminate vagueness as to the amount of experience.” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“C. Claim Construction The parties agree that no claim terms require express construction. Pet. 4; Prelim. Resp. 11. On this record, we determine that no terms need express construction. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve” slip op. at 5
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundOther
“expressly discloses multiple options for resetting the timer, including “after the STA 106 transmits a scheduled UL transmission, or transmits a scheduled UL transmission and gets an ACK message.” Ex. 1005 ¶ 81. We find sufficiently persuasive Petitioner’s explanation that “after” in Zhou means after the transmission ends if an ACK is not requested; in the case of an ACK, Zhou expressly discloses starting the timer after receiving the ACK. See Pet. 46–49. Petitioner’s declarant, Dr. Valenti, testifies that “[a] STA measures the ‘completion’ of the transmission by receiving an ACK— if an ACK is requested—or upon completion of the physical transmission.” Ex. 1003 ¶ 152 (citing Ex. 1018 ¶ 9). On this record, we find this testimony to be sufficiently credible based on the evidence cited. See Ex. 1018 ¶ 9 (“A successful transmission occurs when the node either receives an expected acknowledgment correctly, or transmits a frame that does not require an acknowledgement.”).” slip op. at 13
Claim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,116,035 - PTAB · Nov 6, 2025 · IPR2025-00936 · APJ Daniel J Galligan · IPR · Institution
The Board instituted IPR on claims 1–16 over all petitioned grounds, finding a reasonable likelihood of prevailing on at least claim 1 over Lee.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“On this record, we find Petitioner’s contentions persuasive. As noted above, Lee states the following: “[I]f the coloring disable bit indicates that the frame corresponds to a trigger frame related to multiuser transmission, the STA may not perform the change of the CCA level irrespective of information indicated by the coloring bit.” Ex. 1005 ¶ 68. Even though the coloring disable bit indicates that the frame corresponds to a trigger frame for multiuser transmission, Lee states that “the coloring disable bit can also be comprehended as a bit indicating that CCA level change is not performed.” Ex. 1005 ¶ 68. This supports Petitioner’s contention that the coloring disable bit is signaling information that indicates that a CCA level change is not allowed, even if it indicates other things as well. See Pet. 12.” slip op. at 10
- Skill levelSkill level petitioner adoptedDecided for petitioner
“To the extent Patent Owner contends that a person of ordinary skill in the art need not be defined as of the critical date, we disagree. Under Section 103, we must determine “if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains” (emphasis added). “Obviousness is determined from the vantage point of a hypothetical person having ordinary skill in the art to which the patent pertains.” In re Rouffet, 149 F.3d 1350, 1357 (Fed. Cir. 1998). Thus, we define the hypothetical person of ordinary skill in the art as of a time before the effective filing date. To the extent Patent Owner’s argument is that, to testify from the perspective of a person of ordinary skill in the art, one need not have been a person of ordinary skill in the art as of the critical date, we agree. Although one must at least possess ordinary skill in the art to testify from the perspective of a person of ordinary skill, 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. Osseo Imaging, LLC v. Planmeca USA Inc., 116 F.4th 1335, 1341 (Fed. Cir. 2024). To the extent necessary, and for purposes of this Decision, we accept the uncontested assessment offered by Petitioner, which appears consistent with the ’597 patent and the asserted prior art, except that we delete the qualifier “at least” to eliminate vagueness as to the amount of experience.” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“C. Claim Construction The parties agree that no claim terms require express construction. Pet. 3; Prelim. Resp. 8. On this record, we determine that no terms need express construction. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 6
- BurdenInstituted
“On this record, we find Petitioner’s contentions persuasive. As noted above, Lee states the following: “[I]f the coloring disable bit indicates that the frame corresponds to a trigger frame related to multiuser transmission, the STA may not perform the change of the CCA level irrespective of information indicated by the coloring bit.” Ex. 1005 ¶ 68. Even though the coloring disable bit indicates that the frame corresponds to a trigger frame for multiuser transmission, Lee states that “the coloring disable bit can also be comprehended as a bit indicating that CCA level change is not performed.” Ex. 1005 ¶ 68. This supports Petitioner’s contention that the coloring disable bit is signaling information that indicates that a CCA level change is not allowed, even if it indicates other things as well. See Pet. 12.” slip op. at 10
Claim constructioncites KSR · GrahamPatents in suitUS 11,700,597 - PTAB · Nov 6, 2025 · IPR2025-00935 · APJ Daniel J Galligan · IPR · Institution
The Board instituted IPR of claims 1–16 on all petitioned grounds, finding a reasonable likelihood that Samsung would prevail on at least one challenged claim.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“On this record, we find Petitioner’s contentions persuasive. As noted above, Lee states the following: “[I]f the coloring disable bit indicates that the frame corresponds to a trigger frame related to multiuser transmission, the STA may not perform the change of the CCA level irrespective of information indicated by the coloring bit.” Ex. 1005 ¶ 68. Even though the coloring disable bit indicates that the frame corresponds to a trigger frame for multiuser transmission, Lee states that “the coloring disable bit can also be comprehended as a bit indicating that CCA level change is not performed.” Ex. 1005 ¶ 68. This supports Petitioner’s contention that the coloring disable bit is signaling information that indicates that a CCA level change is not allowed, even if it indicates other things as well. See Pet. 13.” slip op. at 10
- Skill levelSkill level petitioner adoptedOther
“To the extent Patent Owner contends that a person of ordinary skill in the art need not be defined as of the critical date, we disagree. Under Section 103, we must determine “if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains” (emphasis added). “Obviousness is determined from the vantage point of a hypothetical person having ordinary skill in the art to which the patent pertains.” In re Rouffet, 149 F.3d 1350, 1357 (Fed. Cir. 1998). Thus, we define the hypothetical person of ordinary skill in the art as of a time before the effective filing date. To the extent Patent Owner’s argument is that, to testify from the perspective of a person of ordinary skill in the art, one need not have been a person of ordinary skill in the art as of the critical date, we agree. Although one must at least possess ordinary skill in the art to testify from the perspective of a person of ordinary skill, 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.” slip op. at 5
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“C. Claim Construction The parties agree that no claim terms require express construction. Pet. 3; Prelim. Resp. 8. On this record, we determine that no terms need express construction. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 6
- Obviousness (§103) › Motivation to combine / reasonable expectation of successOther
“On this record, it is not entirely clear that comparing a BSS color value to determine if a receiving station is in that BSS is prohibited by the claim’s recitation “not to use” a BSS color, as Patent Owner’s argument implies. Rather, claim 1’s recitation “not to use a Basic Service Set (BSS) color when signaling information indicates that an operation based on the BSS color is not allowed” appears directed to prohibiting a particular operation based on the BSS color, not necessarily disregarding the BSS color entirely. Further, comparing BSS values to determine BSS identity appears consistent with claim 1’s recitation that “the BSS color is an communication terminal recognizes that a BSS color collision has occurred.” On this record, it appears that BSS color would need to be identified to determine if a color collision occurs. See Prelim. Resp. 4 (“BSS color collisions occur when two or more BSSs operating on the same frequency channel (and overlapping in coverage area) use the same BSS color. See ’163 Patent at 2:46-59, 10:41-62. In other words, a wireless communication terminal receives a signal with the same BSS color that device understands applies to it, even though the signal is intended for another device in a different BSS (albeit using the same BSS color). When a color collision is detected, the wireless communication terminal reports to the base wireless communication terminal, which will indicate that a color collision has occurred. ’163 Patent at 3:16-20.”). In that light, we see some merit in Petitioner’s position that an “operation based on BSS COLOR (e.g., allowing access and re-using the channel) is not allowed” based on the Low Power/High Interference Indicator, even if some reference is made to the BSS color to resolve a condition precedent to that determination, namely whether the data are from a different BSS. See Pet. 53–54 (citing Ex. 1009 ¶ 26; Ex. 1003 ¶ 170). Petitioner’s second theory is based on setting the color field to a reserved value of “0000,” which Petitioner argues “indicates that operations based on BSS COLOR are not allowed and the receiving STA does not use BSS COLOR.” Pet. 54–55 (citing Ex. 1009 ¶¶ 25, 29; Ex. 1003 ¶ 172). On this record, we question how setting a color value to 0000 can teach the subject matter of claim 1, which also requires that “the BSS color is an identifier of a BSS.” Petitioner acknowledges that a reserved value of 0000 in the color field does not identify a BSS. See Pet. 54–55 (asserting that a that a COLOR field value of ‘0000’ does not represent a valid BSS identifier”). We also recognize, however, that claim 7, depending from claim 1, recites “the BSS color indicated by the signaling field of the PPDU is a predetermined value” and that claim 8, depending from claim 7, recites that the predetermined value is 0. Thus, Choudhury’s reserved value disclosures appear to teach this subject matter of claims 7 and 8, even if claims 7 and 8 are inconsistent with claim 1’s requirement that “the BSS color is an identifier of a BSS.” See Ex. 1001, 21:23–30 (disclosing that the BSS color value may be set to a predetermined value such as zero).” slip op. at 12
Claim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,129,163 - PTAB · Nov 3, 2025 · IPR2025-00934 · APJ Terrence W Mcmillin · IPR · Institution
The Board instituted IPR on claims 1–9 and all asserted grounds, finding a reasonable likelihood that claims 1–9 are obvious over Bharadwaj and Sun.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“institute review. Paper 11. The standard for institution is set forth in 35 U.S.C. § 314(a), which provides that inter partes review may not be instituted unless “there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” After considering the Petition and the Preliminary Response, as well as the evidence of record, we institute an inter partes review as to claims 1–9 of the ’210 patent.” slip op. at 2
- Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication establishedNot reached
“We are aware, however, that we must not confuse access with accessibility. See Samsung Elecs. Co. v. Infobridge Pte. Ltd., 929 F.3d 1363, 1374 (Fed. Cir. 2019) (“[A] petitioner need not establish that specific persons actually accessed or received a work to show that the work was publicly accessible.”). Dr. Hansen notes that the cover of 802.11ax_D1.0 grants permission to reproduce the document to others for consideration. Ex. 1026 ¶ 72; see Ex. 1004, 1 (“Permission is hereby granted for IEEE Standards Committee participants to reproduce this document for purposes of international standardization consideration.”). Dr. Hansen also testifies that meetings to discuss 802.11ax_D1.0 were open to the public. Ex. 1026 ¶ 58 (citing Appendix J to declaration). Thus, it appears, on the current record, that the purpose of 802.11ax_D1.0 was to promote dialogue with interested artisans, which indicates public accessibility. See Valve Corp. v. Ironburg Inventions Ltd., 8 F.4th 1364, 1374 (Fed. Cir. 2021) (“We have previously held that where a publication’s purpose is ‘dialogue with the intended audience,’ that purpose indicates public accessibility.” (citation omitted)). After having reviewed all the arguments and evidence presented by the parties, we would like to see further development of this issue during trial. The current record is not well-developed on this issue either factually or legally. With regard to the factual record, Patent Owner has not yet had the opportunity to depose Dr. Hansen or been given a full opportunity to marshal its own evidence on this issue. With regard to the law, we would like to see the parties apply the relevant case law to the developed facts as to the public accessibility and prior art status of 802.11ax_D1.0. We will determine, if necessary and appropriate, whether 802.11ax_D1.0 is prior art to the challenged claims of the ’210 patent based on the full record as developed during trial.” slip op. at 14
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner
“As an initial matter, Bharadwaj and Sun are both analogous art to the ’210 Patent in that that they are both concerned with the design of the PHY data unit for supporting MU-MIMO transmissions in the downlink. SAMSUNG-1003, ¶¶153- 158. . . . In addition, both Bharadwaj and Sun describe MU- MIMO downlink PHY data unit structures in the context of 802.11ax. SAMSUNG-1013, ¶[0064]; SAMSUNG-1015, ¶[0031]; SAMSUNG-1003, ¶¶153-158. . . . . [A] POSITA implementing Bharadwaj’s preamble designs would have been motivated to look to another reference, like Sun, for an understanding of the format of the user field that would support non-MU-MIMO allocations and the single-user transmission scenario. A POSITA would have combined the teachings of Bharadwaj with Sun to realize implementation details for the HE-SIG-A and HE-SIG-B fields of the HE MU PPDU to better support both MU-MIMO and non-MU-MIMO allocations. SAMSUNG-1003, ¶¶153-158. . . . . A POSITA would have found it obvious to look to Sun for modifying Bharadwaj to include the user field format for SU (non-MU-MIMO) allocation to complement Bharadwaj’s disclosure of the MU-MIMO user field format and to provide a more complete system that would allow HE MU PPDUs to support both MU-MIMO allocations for multiple users and non-MU-MIMO allocations for a single user. SAMSUNG- 1003, ¶¶153-158. The combination also would have been obvious and predictable for at least the following reasons: 1) both Bharadwaj and Sun describe designs for a PHY data unit (or PPDU) to support communications between an AP and a station within a high-efficiency Wi-Fi network, consistent with 802.11ax; 2) both Bharadwaj and Sun describe the PPDU design for supporting MU-MIMO downlink transmission as including HE- SIG-A and HE-SIG-B fields; and 3) Bharadwaj already describes the format for the user field for the MU-MIMO allocation, while also recognizing the single-user scenario, and the combination merely involves the addition to Bharadwaj of the user field format for the single-user allocation, as taught by Sun. SAMSUNG-1003, ¶¶153- 158. The combination is obvious also because elements of the combined system would each perform similar functions they had been known to perform in similar contexts outside the combination. SAMSUNG-1003, ¶¶153-158. . . . . A POSITA would have reasonably expected success implementing the combination, especially considering the substantially similar 802.11ax techniques described in each reference. SAMSUNG-1003, ¶¶153-158. Additionally, combining the teachings of Bharadwaj with Sun would have merely involved combining prior art elements according to known methods to yield predictable results. SAMSUNG-1003, ¶¶153-158.” slip op. at 31
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner
“Petitioner asserts that “no formal claim constructions are necessary.” Pet. 2. Patent Owner notes that “both parties have submitted terms for construction in the district court for this Patent” (Prelim. Resp. 6), but that “for purposes of [the] Preliminary Response, Patent Owner applies the plain and ordinary meaning of the challenged claims” (id. at 8). Accordingly, at this stage, no need exists to expressly construe any claim terms to resolve the parties’ disputes.9 See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 9
Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,159,210 - PTAB · Aug 27, 2025 · IPR2025-00574 · APJ Beth Z Shaw · IPR · Institution
The Board instituted IPR of claims 1–7 on all asserted grounds after finding a reasonable likelihood that Petitioner would prevail on claim 1 over Choe and Workman.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“For purposes of institution, we find sufficient Dr. Darrell’s testimony that a person of ordinary skill in the art would have been motivated to combine Choe and Workman because Workman discloses predictive models to identify the horizon line (Ex. 1003 ¶ 146), and additionally, because using Workman’s model to identify the horizon line would have been combining known elements (CNNs and annotation for camera calibration) according to known methods to yield predictable results and used known techniques (CNNs) to improve similar devices in the same way. Pet. 48 (citing Ex. 1003 ¶ 150). We find sufficient for institution Dr. Darrell’s testimony that because these models were well known, a person of skill in the art would have had a reasonable expectation of success in combining the teachings of Choe and Workman to achieve the method of claim 1. Id. at 49 (citing Ex. 1003 ¶ 150). We have reviewed Mr. Andrews’s testimony to the contrary (Ex. 2003 ¶¶ 71–80) but, at this stage, do not find it persuasive. For example, to the extent Patent Owner and Mr. Andrews assert that Choe does not identify any “shortcomings” that would motivate a POSITA to look for a better approach like that of Workman (see Prelim. Resp. 29; Ex. 2003 ¶ 74), we note that it is “not necessary to show that a combination is ‘the best option, only that it be a suitable option,’” and “if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious unless its actual application is beyond his or her skill,” Intel Corp. v. Qualcomm Inc., 21 F.4th 784, 800 (Fed. Cir. 2021) (citations omitted). Thus, at this stage and on this record, we preliminarily agree that the combination of Choe and Workman teaches the subject matter of limitation [1B] sufficiently to meet Petitioner’s burden on institution.” slip op. at 11
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundInstituted
“For purposes of institution, we find sufficient Dr. Darrell’s testimony that a person of ordinary skill in the art would have been motivated to combine Choe and Workman because Workman discloses predictive models to identify the horizon line (Ex. 1003 ¶ 146), and additionally, because using Workman’s model to identify the horizon line would have been combining known elements (CNNs and annotation for camera calibration) according to known methods to yield predictable results and used known techniques (CNNs) to improve similar devices in the same way. Pet. 48 (citing Ex. 1003 ¶ 150). We find sufficient for institution Dr. Darrell’s testimony that because these models were well known, a person of skill in the art would have had a reasonable expectation of success in combining the teachings of Choe and Workman to achieve the method of claim 1. Id. at 49 (citing Ex. 1003 ¶ 150). We have reviewed Mr. Andrews’s testimony to the contrary (Ex. 2003 ¶¶ 71–80) but, at this stage, do not find it persuasive. For example, to the extent Patent Owner and Mr. Andrews assert that Choe does not identify any “shortcomings” that would motivate a POSITA to look for a better approach like that of Workman (see Prelim. Resp. 29; Ex. 2003 ¶ 74), we note that it is “not necessary to show that a combination is ‘the best option, only that it be a suitable option,’” and “if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious unless its actual application is beyond his or her skill,” Intel Corp. v. Qualcomm Inc., 21 F.4th 784, 800 (Fed. Cir. 2021) (citations omitted). Thus, at this stage and on this record, we preliminarily agree that the combination of Choe and Workman teaches the subject matter of limitation [1B] sufficiently to meet Petitioner’s burden on institution.” slip op. at 11
- Skill levelOther
“would have had a Bachelor’s in Computer Science with a focus on computer/machine vision, and at least two years of experience with each of: (1) machine learning (including neural network) methods as applied to machine/computer vision and (2) classical machine/computer vision algorithms (e.g., edge detection, line identification, computation of camera parameters from horizon line, etc.)” and that additional education “could serve as a substitute for the experience requirement.” Pet. 7–8 (citing Ex. 1003 ¶ 77). Patent Owner disagrees with Petitioner’s definition and asserts that a POSITA “would have a bachelor’s degree in engineering or computer science with one- or two-years training and/or experience in design of software for camera/sensor systems in the automotive industry.” Prelim. Resp. 12 (citing Ex. 2003 (Declaration of Scott Andrews) ¶ 35). We determine that no express finding is necessary, on the present record, and that the level of ordinary skill in the art is reflected by the prior art of record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978). The difference in how each party characterizes a POSITA’s work experience does not change our analysis or conclusions based on the present record. Should the parties continue to disagree regarding the level of ordinary skill in the art during trial, we encourage the parties to explain how an automotive-focused definition, or the lack thereof, would affect any obviousness analysis in our final written decision. B. slip op. at 5
- Expert testimonyOther
“For purposes of institution, we find sufficient Dr. Darrell’s testimony that a person of ordinary skill in the art would have been motivated to combine Choe and Workman because Workman discloses predictive models to identify the horizon line (Ex. 1003 ¶ 146), and additionally, because using Workman’s model to identify the horizon line would have been combining known elements (CNNs and annotation for camera calibration) according to known methods to yield predictable results and used known techniques (CNNs) to improve similar devices in the same way. Pet. 48 (citing Ex. 1003 ¶ 150). We find sufficient for institution Dr. Darrell’s testimony that because these models were well known, a person of skill in the art would have had a reasonable expectation of success in combining the teachings of Choe and Workman to achieve the method of claim 1. Id. at 49 (citing Ex. 1003 ¶ 150). We have reviewed Mr. Andrews’s testimony to the contrary (Ex. 2003 ¶¶ 71–80) but, at this stage, do not find it persuasive. For example, to the extent Patent Owner and Mr. Andrews assert that Choe does not identify any “shortcomings” that would motivate a POSITA to look for a better approach like that of Workman (see Prelim. Resp. 29; Ex. 2003 ¶ 74), we note that it is “not necessary to show that a combination is ‘the best option, only that it be a suitable option,’” and “if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious unless its actual application is beyond his or her skill,” Intel Corp. v. Qualcomm Inc., 21 F.4th 784, 800 (Fed. Cir. 2021) (citations omitted).” slip op. at 11
§ 103 obviousnessPatents in suitUS 11,875,580
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.