- CSPC Megalith Biopharmaceutical Co., Ltd. v. Lepu Biopharma Co. Ltd.All claims unpatentablePTAB · Oct 8, 2026 · IPR2025-00685 · APJ Ryan H Flax · IPR · Final written decision
Claims 1–23 are unpatentable as obvious over Wei and Liu, and over Leanna, Wei, and Liu.
In the decision…36 (“[Objective indicia] may also serve to guard against slipping into use of hindsight, and to resist the temptation to read into the prior art the teachings of the invention in issue.” (internal quotation marks and citation omitted)). Therefore, we consider this issue from the outset. 20…
RulingsFinal written decision- Skill levelSkill level board ownDecided for petitioner
“appears to be generally consistent with the level of skill presented in the cited prior art. See generally, e.g., Exs. 1005–1008; see also Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art itself may reflect an appropriate level of skill in the art). However, as at institution, we reject the portion of Petitioner’s proposed definition that includes having “access to other individuals with that knowledge and experience,” as not reflecting the individual level of skill of a given skilled artisan. See, e.g., Custom Accessories, Inc. v. Jeffrey-Allan Indus., Inc., 807 F.2d 955, 962 (Fed. Cir. 1986) (holding that “[t]he person of ordinary skill is a hypothetical person who is presumed to be aware of all the pertinent prior art.”) (emphasis added, footnotes omitted); but see Indivior Inc. v. Dr. Reddy’s Labys., S.A., 930 F.3d 1325, 1343 (Fed. Cir. 2019) (no clear error in determination that “a person of ordinary skill . . . ‘would be on a team with an engineer or scientist . . . .’”). Consequently, we find the person of ordinary skill in the art was a person who had a Ph.D. in immunology, molecular biology, cellular biology, or a similar field, or an M.D. with similar experience, and had at least five years of experience with antibodies and antibody engineering.” slip op. at 11
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner submits that no term of the Challenged Claims requires construction to resolve the challenges in this Petition.” Pet. 32. We did not construe any terms in our Institution Decision. See DI 6–7. Patent Owner presents no express positions on claim construction. See generally Resp. For the purposes of this Decision, no terms of the challenged claims require construction. Phillips, 415 F.3d at 1312–13. D. slip op. at 12
- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
“2 G. Wei et al., US 2015/0071923 Al, pub. March 12, 2015. Ex. 1005 (“Wei”). 3 J. Liu, CN 103772504 A, pub. May 7, 2014. Ex. 1007. The Liu reference is published in Simplified Chinese and Petitioner filed a certified English translation, to which we refer herein. See Ex. 1008 (“Liu”). Patent Owner does not contest the accuracy of the translation. See generally Resp. 4 M.R. Leanna & C.L. Becker, WO 2014/152199 A1, pub. Sept. 25, 2014. Ex. 1006 (“Leanna”). 5 Based on our review of each deposition transcript in view of the record as a whole, although each witness appears competent, we are left with the impression that Dr. Bournazos’s testimony is somewhat more credible than Dr. Atanackovic’s. This conclusion is based, inter alia, on each witness’s ability to recall the relevant record and respond to questions on evidentiary and technical issues.” slip op. at 8
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“We find that combining Liu’s BA03 antibody with Wei’s ADC platform would have been desirable, predictable, and routine for the ordinarily skilled artisan based on the facts that: (1) cetuximab was a wellknown and well-studied, U.S. regulatory approved, anti-EGFR antibody that would have served as a starting point for new cancer therapies; (2) humanization of therapeutic antibodies is generally desired (and “[e]very antibody can be humanized” and it is advantageous according to Patent Owner’s counsel); (3) BA03 was a well-known humanized version of cetuximab that had several known advantages over cetuximab in addition to lower immunogenicity from humanization; and (4) Wei taught a similar cetuximab-derived antibody, and a humanized cetuximab-derived antibody, each provided in an ADC with a well-known and validated off-the-shelf linker-drug platform, i.e., vc-MMAE, that exhibited a strong anti-tumor response. See, e.g., Ex. 1001, 1:57–2:32, 2:50–3:1, 5:6–53, 18:3–33, 19:26– 29; Ex. 1002 ¶¶ 14, 38, 42–43, 45–53, 56–73, 84–92, 109–117, 178–189, 202–271; Ex. 1005 ¶¶ 9–10, 229–232, 434, 437, 476, 491–506, 664–675, 685, 688, 715, 732, 1103, 1092–1141; Ex. 1008 ¶¶ 3–6, 60, 74, 141–160; Ex. 2027 ¶¶ 7–8, 38, 50, 57 (confirming our understandings regarding the claimed antibody and linker-drug payload); Ex. 2023, 173, 300; see also Resp. 1, 5–6, 23 (Patent Owner made the “choice” to use the prior-art-known BA03 antibody, and known-candidate cytotoxic payload MMAE); Hr’g Tr. 34:20–23, 36:6–38:20, 47:16–50:16 (Patent Owner’s counsel’s argument). When Liu’s BA03 antibody is provided in an ADC with a vc- MMAE or a Mc-vcPAB-MMAE platform (and used as cancer therapy as the references instruct) the invention of the challenged claims is achieved.” slip op. at 52
Patent outcomesUS 10,792,370 unpatentableClaim construction§ 103 obviousnesscites Phillips · GrahamPatents in suitUS 10,792,370 - GD Energy Products, LLC v. Kerr Machine CompanyAll claims unpatentablePTAB · Jun 29, 2026 · PGR2025-00031 · APJ Ryan H Flax · PGR · Final written decision
Claims 1–14 are unpatentable as obvious under each of four asserted grounds: Kerr; Aplex and Stanton; Blume, Stanton, and Wilkinson; and the sale of the Kerr Pump.
In the decision…bores, valves, plate, component, plunger, seals, and packing nut elements as claim 1. Petitioner points to the same disclosures of Kerr as teaching such elements. Pet. 56– (citing, inter alia, Ex. 1003 ¶¶ 123–143). None of this is contested, and we find Kerr also teaches each element of…
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“The person of ordinary skill in the art would have a minimum of a bachelor’s degree in mechanical or petrochemical engineering, or a comparable engineering discipline, and a minimum of 3-5 years of work experience in the design and/or manufacturing of reciprocating pumps and valves, including fluid ends and/or comparable high pressure fluid components, for industrial applications, including for use in the oil and gas industry. See, e.g., EX1003, ¶32.” slip op. at 12
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’” 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)). We decline to expressly construe any claim language. slip op. at 12
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“Regarding the combining of Aplex and Stanton, Petitioner asserts that the ordinarily skilled artisan would have understood that providing a packing/stuffing arrangement, as taught by Stanton, within a fluid end housing, as taught by Aplex, would improve pressure and fluid isolation compared with an arrangement where the packing was bolted to the outside of the fluid end as in Aplex unmodified. Pet. 66 (citing Ex. 1003 ¶¶ 189, 236). Patent Owner does not dispute this rationale. We find this to be a reason, with rationale underpinning, why the person of ordinary skill in the art would have combined these references with a reasonable expectation of success.” slip op. at 29
- Adverse judgmentOther
“The record indicates that Patent Owner has statutorily disclaimed claim 15 as of April 28, 2025. Ex. 2206.” slip op. at 8
Patent outcomesUS 12,152,582 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 12,152,582 - Qiagen Sciences, LLC v. Tecan Genomics, Inc.All claims unpatentablePTAB · May 13, 2026 · IPR2025-00028 · APJ Zhenyu Yang · IPR · Final written decision
Claims 1–15 and 17–22 are unpatentable as obvious over the specified combinations of Shapero, Delseny, and, for certain claims, Hamady or Jones.
In the decision…Cir. 2016) (stating that a party that asserts obviousness of a claim must show that “a skilled artisan 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…
RulingsFinal written decision- Skill levelSkill level board ownDecided for patent owner
“In the DI, we addressed Patent Owner’s arguments disputing Petitioner’s proposed definition. DI 17–18 (citing Prelim. Resp. 11–12). We stated that for purposes of this Decision, we find a POSA would have had a Ph.D. in molecular biology, molecular genetics, bioinformatics, biochemistry, or a related field. Alternatively, a POSA would have had a B.S. or M.S. degree with three to five years of experience working in any of those fields. Additionally, the POSA would have had experience with NGS sequencing methods and a working knowledge of how those methods functioned. Id. at 18. After institution, Patent Owner states that, for purposes of this proceeding, it adopts the Board’s definition of a POSA. PO Resp. 12. Based on the entirety of the trial record, we maintain our finding of a POSA’s skill level.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“Claim Construction In an inter partes review, we construe a claim term “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).” 37 C.F.R. § 42.100(b) (2020). Under that standard, the words of a claim “are generally given their ordinary and customary meaning,” which is “the meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention, i.e., as of the effective filing date of the patent application.” Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc). Claim terms need only be construed to the extent necessary to resolve the controversy. Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011). On this record and for purposes of this Decision, we see no need to construe any claim term expressly.” slip op. at 9
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
- Obviousness (§103) › Motivation to combine / reasonable expectation of success › Teaching awayTeaching away not foundDecided for petitioner
“A reference teaches away “when a person of ordinary skill, upon reading the reference, would be discouraged from following the path set out in the reference, or would be led in a direction divergent from the path that was taken by the applicant.” In re Fulton, 391 F.3d 1195, 1201 (Fed. Cir. 2004). “The prior art’s mere disclosure of more than one alternative does not constitute a teaching away from any of these alternatives because such disclosure does not criticize, discredit, or otherwise discourage the solution claimed.” Id.” slip op. at 29
Patent outcomesUS 10,036,012 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,036,012 - Qiagen Sciences, LLC v. Tecan Genomics, Inc.All claims unpatentablePTAB · May 13, 2026 · IPR2025-00029 · APJ Zhenyu Yang · IPR · Final written decision
Claims 1–12 and 14–19 are unpatentable as obvious over the listed combinations; Petitioner’s motion to strike is denied.
In the decision…end our inquiry. After all, a party that asserts obviousness of a claim must show that “a skilled artisan 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…
RulingsFinal written decision- Skill levelSkill level board ownDecided for petitioner
“for purposes of this Decision, we find a POSA would have had a Ph.D. in molecular biology, molecular genetics, bioinformatics, biochemistry, or a related field. Alternatively, a POSA would have had a B.S. or M.S. degree with three to five years of experience working in any of those fields. Additionally, the POSA would have had experience with NGS sequencing methods and a working knowledge of how those methods functioned.” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“claim construction standard that would be used to construe the claim in a civil action under 35 U.S.C. [§] 282(b).” 37 C.F.R. § 42.100(b) (2020). Under that standard, the words of a claim “are generally given their ordinary and customary meaning,” which is “the meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention, i.e., as of the effective filing date of the patent application.” Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc). Claim terms need only be construed to the extent necessary to resolve the controversy. Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011). On this record and for purposes of this Decision, we see no need to construe any claim term expressly.” slip op. at 8
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
- Obviousness (§103) › Motivation to combine / reasonable expectation of success › Teaching awayTeaching away not foundDecided for petitioner
Patent outcomesUS 10,876,108 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,876,108 - First Quality Retail Services, LLC / First Quality Consumer Products, LLC et al. v. Essity Hygiene And Health ABAll claims unpatentablePTAB · May 12, 2026 · IPR2024-01487 · APJ Kristina M Kalan · IPR · Final written decision
Claims 1–5, 7, 8, 20–22, 24, and 25 are unpatentable, based on anticipation by Bergstrom and obviousness over the stated combinations.
In the decision…that the problem with Petitioner’s “structure” argument is three-fold: (1) it assumes liquid permeability of forming element 60 without any express teaching; (2) forming element 60 is “no more part of a fluid flow control structure than a backsheet; and (3) there is no fluid flow in the…
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“In the Institution Decision, we adopted Petitioner’s definition. Dec. 9–10. In its Response, Patent Owner cites to Petitioner’s definition and states that Patent Owner “applies Petitioners’ definition.” PO Resp. 7. Because Petitioner’s definition of the level of skill in the art is consistent with the ’138 patent and the asserted prior art, we maintain it for purposes of this Final Written Decision. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for petitioner
“We begin our analysis with the language of the claims. Phillips, 415 F.3d at 1312; see also SuperGuide Corp. v. DirecTV Enterprises, Inc., 358 F.3d 870, 874–875 (Fed. Cir. 2004) (“There is a ‘heavy presumption’ that the terms used in the claims ‘mean what they say and have the ordinary meaning that would be attributed to those words by persons skilled in the relevant art.’”). Claim 1 recites, in relevant part, “said fluid flow control structure being a layered structure comprising a non-perforated fibrous polymeric layer and a first perforated polymeric layer.” Ex. 1001, 13:62–64 (limitation [1h]). The plain language of claim 1 does not address additional properties of the perforated polymeric layer; the language of the dependent claims, however, imposes additional limitations on the properties of the perforated polymeric layer such as a particular basis weight (claim 2), a particular makeup (claim 3), a particular aperture size (claim 7), a particular open area (claim 8), and that it “is a three-dimensionally formed layer having penetrating apertures extending from a first surface of the first perforated polymeric layer towards a second surface of the first perforated polymeric layer and forming protrusions on said second surface” (claim 4). The dependent claims’ additional language indicates that the term “perforated” within the term “perforated polymeric layer” in claim 1 is not limited in the manner asserted by Patent Owner’s proposed construction.” slip op. at 12
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“layer pierced through with holes or apertures,” we are persuaded that Petitioner meets its burden as to this limitation. Petitioner argues that under our construction, Bergstrom’s express disclosure of forming element 60, and Bergstrom’s explanation of the properties of forming element 60, meets the claimed “perforated polymeric layer” limitation. Pet. 38–41 (citing Ex. 1002 ¶¶ 114–117). Even under Patent Owner’s proposed construction, Petitioner argues, forming element 60 would also allow free flow of liquid bodily waste. Pet. Reply 3– 4 (citing Ex. 1021 ¶¶ 20–23). Importantly, Bergstrom expressly discloses: “suitable materials for the forming element 60 are plastic films, perforated plastic films and reinforced tissue or reinforced nonwoven materials.” Ex. 1004, 10:1–4. This express disclosure is clear. Even though the forming element 60 in Bergstrom might be “typically” liquid-impermeable (Ex. 1004, 9:24–30), that does not preclude a layer that is perforated, particularly where Bergstrom expressly discloses a perforated plastic film as one of the possibilities for forming element 60. Ex. 1004, 10:1–4. Additionally, although Patent Owner focuses on Bergstrom’s disclosure that forming element 60 is “typically liquid-impermeable” (PO Resp. 58–60; Ex. 1004, 9:24–30), we do not view Bergstrom’s use of the word “typically” as mandating that the forming element always be liquid impermeable. We agree that the word “typically” does not mean “always” and that such a reading would render “typically” superfluous. Pet. Reply. 5. We do not find any ambiguity in Bergstrom’s disclosure regarding possible use of perforated plastic films for its forming element 60; whether or not the forming element 60 provides other functions (like stiffness) does not dictate whether it may also be perforated, or be part of a fluid flow control structure. On this point, we credit Petitioner’s arguments and explanation, as supported by Dr. Pourdeyhimi’s testimony. Pet. Reply 6–7; Ex. 1021 ¶ 27–28 (“components of absorbent articles could be multifunctional”).” slip op. at 20
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“from the start” (PO Resp. 29), and that “using all or part of [Glaug’s] fluid-acquisition system in place of [Nakazawa’s] diffusion sheet would be antithetical to the teachings of both references” (id. at 35), we agree that the proposed combination of Nakazawa’s structure with the layers of Glaug is sufficiently motivated and reasonably expected to result in a successful article, for the reasons articulated by Petitioner. See, e.g., Pet. 59–65; Ex. 1002 ¶¶ 176–192. Namely, although fluid may flow in both Z directions in Nakazawa (PO Resp. 30), that does not foreclose the combination with Glaug in the manner proposed by Petitioner. See generally Ex. 1002 ¶¶ 176–192; see id. ¶ 184 (detailing the mechanics of the proposed combinations), ¶¶ 188–191 (discussing motivation to combine), ¶ 192 (discussing reasonable expectation of success). The combination can be achieved “either by adding the lower acquisition layer 64 [of Glaug] to diffusion sheet 63 [of Nakazawa], or by replacing diffusion sheet 63 [of Nakazawa] with the two-layer fluid acquisition system 34 [of Glaug],” and as persuasively explained by Dr. Pourdeyhimi, the arrangement constitutes a “fluid flow control structure.” See Ex. 1021 ¶¶ 45–47. Additionally, the diffusion sheet in Nakazawa can be made from the same material as used in Glaug, namely, AquiDry™. Id. ¶¶ 53–55; see also Tr. 17:25–18:3 (“although Glaug does not specify the name AquiDry in its disclosure, Patent Owner’s expert testified that it’s his understanding that Glaug is discussing the AquiDry material, the same material that is in Nakazawa . . . . they disclose using the same material, and Nakazawa says this material work[s]”). When asked if Patent Owner’s expert had any concerns that AquiDry was not the same as between Nakazawa and Glaug, Patent Owner’s counsel replied “They are the same, Your Honor. And we embrace that.” Tr. 46:8–12; see also id. at 58:19 (Petitioner’s counsel commenting about Patent Owner’s counsel: “they agree, AquiDry is used in both Nakazawa and Glaug”). Thus, Patent Owner’s argument that Nakazawa’s diffusion sheet and Glaug’s fluid acquisition layer have different purposes because Nakazawa’s diffusion sheet allegedly must promote fluid flow in the Z-directions, both toward and away from the body (PO Resp. 29–37; Ex. 2004 ¶¶ 26–28, 30– 35)) is not clearly supported by Nakazawa, and is also contravened by the shared disclosure of Nakazawa and Glaug as to the composition of the disputed layer. We have reviewed the complete record, including Patent Owner’s and Mr. Sheldon’s assertions that Nakazawa requires promoting fluid flow in both Z-directions (see id.), but find that Petitioner carries its burden to demonstrate that one of ordinary skill in the art would have been motivated to combine Nakazawa and Glaug with a reasonable expectation of success. On this complete record, Petitioner explains sufficiently why and how a person of ordinary skill would modify Nakazawa’s diffusion sheet, i.e., to use Glaug’s fluid acquisition system, or the lower non-perforated layer of its fluid acquisition system, in Nakazawa, and Petitioner provides well-supported reasons for doing so.” slip op. at 36
Patent outcomesUS 9,308,138 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 9,308,138 - Illumina Inc. v. Molecular Loop Innovations LLCAll claims unpatentablePTAB · Jan 16, 2026 · IPR2024-00965 · APJ Annette R Reimers · IPR · Final written decision
Claims 1–6 are unpatentable: Gloor anticipates them, Parameswaran and Gloor render them obvious, and Parameswaran, Binladen, and Bentley render claim 6 obvious.
In the decision…the Board for a determination of unpatentability based on obviousness must show that “a skilled artisan 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…
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner asserts that a person of skill in the art (“POSA”) “would have had (i) a Ph.D. in molecular biology, genetics, bioinformatics, or a related field and at least two years of experience in high-throughput sequencing technologies or (ii) a Master’s degree in one of the same fields with at least four years of experience in high-throughput sequencing technologies.” Pet. 18 (citing Ex. 1003 ¶¶ 19–20). Patent Owner states that it adopts Petitioner’s proposal for a POSA for purposes of this proceeding. PO Resp. 13 (citing Ex. 2001 ¶¶ 20–23). After reviewing the record, we adopt Petitioner’s proposed definition of the skill level as it is consistent with the prior art’s demonstration of the level of ordinary skill in the art at the time of the invention. We find both Dr. Spellman and Dr. Adalsteinsson are qualified to opine from the perspective of a POSA, because each has at least ordinary skill in the art. See Ex. 1003 ¶¶ 4–15; Ex. 2001 ¶¶ 4–9.” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“We acknowledge the ambiguous nature of the disputed claim language. On its face, it could require two or more identifier sequences together be uniquely associated with the nucleic acid of interest, as Petitioner argues; or it could require two or more identifier sequences, each individual identifier sequence must be uniquely associated with the nucleic acid of interest, as Patent Owner asserts. See Reply 2–3; Sur-reply 1–6. We, therefore, must examine the words of the claim and the specification to ascertain the scope of this limitation. The specification states that “[w]hile the pair of barcodes associated with any given template is unique, individual barcode sequences can be used with multiple templates as long as no pair is used across two different samples.” Ex. 1001, 2:50–53 (emphasis added). Elsewhere, it states that [t]he first and second identifiers are designed such that each set of identifiers is correlated to a particular sample (e.g., material obtained from a particular patient or group of patients), allowing samples to be distinguished and/or validated. The first and second identifiers may be the same or different, so long as the combination is unique with respect to the sample or sub-sample that one seeks to distinguish and/or validate. Id. at 3:15–22 (emphases added). We agree with Petitioner that the specification supports its proposed construction. See Reply 2.” slip op. at 10
- Claim Construction › Intrinsic evidence (Phillips canons) › Lexicography (patentee as own lexicographer)Term construed patent owner constructionDecided for patent owner
“Claim 5 recites “homopolymer region.” The ’200 patent specification provides an express definition for the term, stating that “the barcode sequences can be designed to have minimal or no homopolymer regions, i.e., 2 or more of the same base in a row such as AA or CCC, within the barcode sequence.” Ex. 1001, 9:6–10. Thus, we agree with Patent Owner that the term “homopolymer region” should be construed as “two or more of the same base in a row.” See PO Resp. 13 (citing Ex. 2001 ¶ 24). Claim terms need only be construed to the extent necessary to resolve the controversy. Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011). On this record and for purposes of this Decision, we see no need to expressly construe any other claim term.” slip op. at 13
- Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication establishedDecided for petitioner
“A reference is considered publicly accessible if it is “made available to the extent that persons interested and ordinarily skilled in the subject matter or art, exercising reasonable diligence, can locate it.” Jazz Pharms., Inc. v. Amneal Pharms., LLC, 895 F.3d 1347, 1355 (Fed. Cir. 2018). To “determine whether an interested researcher would have been sufficiently capable of finding the reference and examining its contents,” we “must consider all of the facts and circumstances surrounding the disclosure.” In re Lister, 583 F.3d 1307, 1312 (Fed. Cir. 2009); see also In re Klopfenstein, 380 F.3d 1345, 1350 (Fed. Cir. 2004) (explaining that a determination of whether a reference qualifies as a printed publication “involves a case-by-case inquiry into the facts and circumstances surrounding the reference’s disclosure to members of the public”).” slip op. at 15
Patent outcomesUS 11,768,200 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,768,200 - Illumina Inc. v. Molecular Loop Innovations LLCNo claims unpatentablePTAB · Jan 13, 2026 · IPR2024-00964 · APJ Annette R Reimers · IPR · Final written decision
Claims 1–8 were not shown unpatentable over either asserted §103 combination because the prior art did not teach the discarding step or establish a reasonable expectation of success.
In the decision…the Board for a determination of unpatentability based on obviousness must show that “a skilled artisan 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…
RulingsFinal written decision- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed patent owner constructionDecided for patent owner
“specification to interpret the meaning of a claim and importing limitations from the specification into the claim can be a difficult one to apply in practice.” Phillips, 415 F.3d at 1323. “[T]he line between construing terms and importing limitations”, however, “can be discerned with reasonable certainty and predictability if [our] focus remains on understanding how a person of ordinary skill in the art would understand the claim terms.” Id. Ultimately, we construe claim terms to “capture the scope of the actual invention more accurately than either strictly limiting the scope of the claims to the embodiments disclosed in the specification or divorcing the claim language from the specification.” Id. at 1324. Here, we are tasked with resolving the dispute between the parties as to the scope of the source of the claimed cross-over error. See Sur-reply 2. Although claim 1 does not explicitly recite cross-over error is created during cluster amplification, the specification shows otherwise. It repeatedly, consistently, and exclusively describes cross-over errors as arising from the formation of chimeric molecules during the amplification step of the sequencing workflow. See Ex. 1001, Fig. 1, Fig. 2, 4:29–52 (describing “improper molecular overlap via formation of a heteroduplex between patient A’s nucleic acid template and patient B’s nucleic acid template” “[w]hen the amplification process begins”), 5:29–58 (the same), 6:25–44 (the same), 6:64–7:23 (the same).” slip op. at 15
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner asserts that a person of skill in the art (“POSA”) “would have had (i) a Ph.D. in molecular biology, genetics, bioinformatics, or a related field and at least two years of experience in high-throughput sequencing technologies or (ii) a Master’s degree in one of the same fields with at least four years of experience in high-throughput sequencing technologies.” Pet. 17 (citing Ex. 1003 ¶¶ 19–20). Patent Owner states that it adopts Petitioner’s proposal for a POSA for purposes of this proceeding. PO Resp. 13 (citing Ex. 2001 ¶¶ 19–22). We adopt Petitioner’s proposed definition of the skill level as it is consistent with the prior art’s demonstration of the level of ordinary skill in the art at the time of the invention. We find both Dr. Spellman and Dr. Adalsteinsson are qualified to opine from the perspective of a POSA, because each has at least ordinary skill in the art. See Ex. 1003 ¶¶ 4–15; Ex. 2001 ¶¶ 4–9.” slip op. at 8
- Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentableReasonable expectation not foundNot shown unpatentable
“The reasonable expectation of success requirement refers to the likelihood of success in combining references to meet the limitations of the claimed invention.” Intelligent Bio-Sys., Inc. v. Illumina Cambridge Ltd., 9 Because, as explained below, we find Petitioner has not met its burden to show reasonable expectation of success, we do not need to address whether Petitioner has shown sufficient reason to combine the asserted references. 821 F.3d 1359, 1367 (Fed. Cir. 2016); see also Allergan, Inc. v. Apotex Inc., 754 F.3d 952, 966 (Fed. Cir. 2014) (stating that “failure to consider the appropriate scope of the . . . patent’s claimed invention in evaluating the reasonable expectation of success . . . constitutes a legal error”). Here, the claimed invention is a method for reducing template cross-over error. Thus, we must determine whether, in December 2010, an ordinarily skilled artisan would have reasonably expected that the combination of Parameswaran and Gloor would reduce template cross-over error. slip op. at 26
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable
“Thus, on this record, we are persuaded by Patent Owner’s argument that Parameswaran’s “unexpected perfect pairings of unmatched forward and reverse barcodes” are not cross-over error. PO Resp. 31 (citing Ex. 2001 ¶¶ 116–123). In addition, as Petitioner acknowledges, Parameswaran merely “distinguished,” but did not “discard” sequences with mismatches. Pet. 34. Parameswaran states that “[t]he low false-discovery rate for perfect matches strengthens the argument that any sequence with both 5’ and 3’ barcode motifs will be placed with reasonable accuracy into the correct bin.” Ex. 1004, 8. But, because Parameswaran achieved a “remarkably low misassignment rate,” it did not discard, but included any sequence with a matched barcode. Id. Indeed, Parameswaran explains that “[f]or our purposes, all sequences with a match to one of the two expected sequence motifs were considered as true members of the corresponding dataset.” Id. In its Reply, Petitioner emphasizes Parameswaran’s language “[f]or our purposes.” Reply 14 (citing Ex. 1004, 8). According to Petitioner, “[a] POSA would have understood from Parameswaran that chimeric sequences could be kept or discarded, depending on the sequencing ‘purpose.’” Id. (citing Ex. 1054 ¶¶ 79–82). Petitioner is asking us to deem unpatentable a claim based on its reading of “for our purposes,” a broad, undefined statement, to mean something specific—a suggestion to discard perfect unexpected pairings, which Parameswaran explicitly did not do. See Ex. 1004, 8. Petitioner has not presented sufficient evidence and persuasive argument for us to do so.” slip op. at 24
Patent outcomesUS 11,041,852 not shown unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,041,852 - PTAB · Dec 10, 2025 · PGR2025-00054 · APJ Ryan H Flax · PGR · Institution
The Board instituted PGR on claims 1–16 on all four grounds, finding at least one claim more likely than not unpatentable based on obviousness, indefiniteness, or lack of written description.
In the decision…Ariad Pharms, Inc. v. Eli Lilly & Co., 598 F.3d 1336, 1344, 1351 (Fed. Cir. 2010) (en banc). “The ‘written description’ requirement serves a teaching function, as a ‘quid pro quo’ in which the public is given ‘meaningful disclosure in exchange for being excluded from practicing the…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“institute trial in a post-grant review. We institute a post-grant review only if the information presented in the petition filed under 35 U.S.C. § 321, if unrebutted, shows that it is more likely than not that at least one claim challenged in the petition is unpatentable. 35 U.S.C. § 324. On the existing record, we conclude that Petitioner demonstrates it is more likely than not that Petitioner would prevail in showing that at least one challenged claim of the ’781 patent is unpatentable under a presented ground. See generally Pet. Therefore, we grant institution of post-grant review. Our reasoning is discussed below.” slip op. at 2
- PTAB / AIA Trials › Real party in interest / privityDecided for petitioner
“STANDING Petitioner states that it certifies that: (1) the ’781 patent is available for post grant review because its earliest claimed effective filing date is October 9, 2018, and the patent issued less than nine months ago, on December 3, 2024; and (2) Petitioner is not barred or estopped from requesting a post grant review on the grounds in this petition. Pet. 5. This is sufficient. See 35 U.S.C. § 100(note)(A)–(B), § 321; 37 C.F.R. § 42.204(a). Patent Owner does not contest standing. See generally Prelim. Resp. B. REAL PARTIES-IN-INTEREST Petitioner states that “[t]he real parties-in-interest are Petitioner Straumann USA, LLC and its affiliates Institut Straumann AG and JJGC Indústria e Comércio de Materiais Dentários S.A.” Pet. 3. Patent Owner raises no objection and itself identifies “Smart Denture Conversions, LLC is the real party-in-interest.” Paper 4, 2; see generally Prelim. Resp. C.” slip op. at 3
- Skill levelSkill level petitioner adoptedDecided for petitioner
“At this point, we find little meaningful difference between the two proposed definitions. In fact, neither does Patent Owner’s witness, Mr. Leinsing, who states that his “opinions would not change under either definition.” Ex. 2011 ¶ 42. And, as set forth above, Patent Owner asserts that, for the sake of its present arguments, it matters not which of the two proposed definitions we use for this proceeding. Prelim. Resp. 21. Thus, at this stage, we accept and use Petitioner’s proposed definition of the ordinarily skilled artisan, which, unlike Patent Owner’s, does not implicate reliance on the knowledge of people other than the individual ordinarily skilled artisan. Petitioner’s definition appears to comport with the level of skill in the art reflected in the prior art of record and the ’781 patent. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (“[T]he prior art itself [may] reflect[] an appropriate level” of ordinary skill in the art) (quoting Litton Indus. Prods., Inc. v. Solid State Sys. Corp., 755 F.2d 158, 163 (Fed. Cir. 1985)). This issue may be further developed at trial by the parties, if desired. C.” slip op. at 19
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“same claim construction standard that is used to construe patent claims in a civil action in federal district court thus, by default, we give claim terms their ordinary and customary meaning, which is “the meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention.” 37 C.F.R. § 42.200(b); Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc). Petitioner indicates that None of the claim terms of claims 1–16 need to be construed to determine the patentability issues presented in this petition. The petition applies the ordinary meaning of the claim language as it would be understood by a POSA after reading the ’781 patent. Ex. 1002, ¶130. Petitioner will propose a construction if Patent Owner argues or the Board determines that one is required for any term. Pet. 31 (citing Ex. 1002). And, Patent Owner presents no express position on claim construction at this point. See generally Prelim. Resp. At this stage of the proceeding, we do not expressly construe any claim terms; however, this position is preliminary and we may change it based on the fully developed record at trial.8 D.” slip op. at 19
Claim construction§ 103 obviousness§ 112 disclosurecites GrahamPatents in suitUS 12,156,781 - Anker Innovations Ltd. v. Powermat Technologies Ltd.All claims unpatentablePTAB · Dec 5, 2025 · IPR2024-00994 · APJ Ken B Barrett · IPR · Final written decision
Claims 1–7 and 9–14 are unpatentable as obvious over the asserted combinations of Onishi, Flowerdew, Baarman392, Partovi, and Tocci.
In the decision…16 IPR2024-00994 Patent 9,048,696 B2 contends that Onishi discloses all or much of the claimed subject matter, and relies on Flowerdew for teaching an alignment mechanism as recited in limitation 1.3. See id. at 14–15, 20–21. Patent Owner argues that Onishi fails to disclose the recited…
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Patent Owner’s proposed experience of two years in the field of wireless/inductive charging is a bit more specific than Petitioner’s proposal of three years of experience with circuits and “familiarity with power electronics and inductive power transfer circuits.” We, however, discern little material difference between the parties’ proposed definitions. Petitioner’s definition is consistent with the level of ordinary skill reflected in the prior art references of record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (recognizing that the prior art itself may reflect an appropriate level of skill in the art). For purposes of this decision, we apply Petitioner’s definition of the person of ordinary skill in the art. We note, however, that were we to adopt Patent Owner’s assessment, the outcome of this Decision would be the same.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed petitioner constructionDecided for petitioner
“Even if the Specification identified “linear regulation/control as being a central aim” of the ’696 patent, Patent Owner has offered no persuasive reason why a linear-control-related limitation should be read into independent claim 1, and we decline to do so. Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367, 1371 (Fed. Cir. 2014) (“While we read claims in view of the specification, of which they are a part, we do not read limitations from the embodiments in the specification into the claims.” (citing Liebel–Flarsheim Co. v. Medrad, Inc., 358 F.3d 898, 904 (Fed. Cir. 2004))); cf. Ex. 1105, 40 (the District Court, in the parallel litigation, excluding a witness’s testimony that the “substantially different” term requires “allow[ance] for some incremental change (increase or decrease) in frequency while remaining in the near-linear/linear regions” because, inter alia, Powermat “fails to offer any particularized arguments explaining why the ‘allow[ance]’ construction is proper.” (alterations in original)). Patent Owner also relies on dependent claim 2, which depends from independent claim 1. PO Resp. 28–29. Dependent claim 2 adds to claim 1 the requirement that the driver be configured to increase and decrease the transmission frequency when a particular signal is received. See Ex. 1001, 28:47–54. Patent Owner asserts that this means that the driver is configured to increase/decrease the “substantially different” frequency, namely a frequency that lies within the near-linear region of a frequency-amplitude graph, and argues that, “[i]n reading claim 2 as a whole, a POSITA would understand that the ’696 Patent is directed to a linear control technique for predictably regulating power transfer.” PO Resp. 28–29 (citing Ex. 2006 ¶ 101). Even if dependent claim 2 called for linear control as Patent Owner appears to assert, we would not read such a limitation into the underlying independent claim. See Karlin Tech., Inc. v. Surgical Dynamics, Inc., 177 F.3d 968, 971–72 (Fed. Cir. 1999) (“The doctrine of claim differentiation . . . normally means that limitations stated in dependent claims are not to be read into the independent claim from which they depend.”); but see PO Sur-reply 4 (arguing for a narrower interpretation of independent claim 1 because it must be read in the context of the entire patent, which includes dependent claim 2). In light of the parties’ agreement and the Specification’s description” slip op. at 15
- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
“Dr. Woods testifies that Onishi’s “Paragraph [0180] is unambiguous that FIG. 4 does not illustrate the frequency-response of a single coil in isolation, but instead illustrates the ‘resonance characteristics of the primary coil L1 and the secondary coil L2’ when the coils are brought in electromagnetic proximity of each other for charging—i.e., in an inductively coupled state.” Ex. 1101 ¶ 18. Dr. Woods, in support of his opinion, notes that Onishi’s legend for Figure 4 describes f0 as the “RESONANCE FREQUENCY IN LOAD-CONNECTED STATE.” Id. We find Dr. Woods’s testimony more credible than Dr. Mercier’s. We disagree with Patent Owner’s argument (PO Resp. 35) that Petitioner’s reliance on Onishi’s Figure 4 is misplaced, and we find that Figure 4 discloses a resonant frequency of the inductive couple between the primary and secondary coils, as recited in limitations 1.4 and 1.7.” slip op. at 32
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“We do not find Patent Owner’s arguments persuasive. We agree with Petitioner that Patent Owner’s arguments are incorrectly premised on a hypothetical combination involving the bodily incorporation of the two references’ specific structures. See Pet. Reply 17. “The test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference . . . . Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art.” In re Keller, 642 F.2d 413, 425 (CCPA 1981); see also In re Sneed, 710 F.2d 1544, 1550 (Fed. Cir. 1983) (“[I]t is not necessary that the inventions of the references be physically combinable to render obvious the invention under review.”); In re Nievelt, 482 F.2d 965, 968 (CCPA 1973) (“Combining the teachings of references does not involve an ability to combine their specific structures.”). Rather, “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.” KSR Int’l Co., 550 U.S. at 417. Petitioner’s proposed combination is the application, to Onishi’s charging system, of Flowerdew’s general teaching of the technique of using an alignment mechanism in order to optimize the alignment of the inductive coils and to maximize the inductive coupling. See, e.g., Pet. 15 (“[A] POSITA would have been motivated to implement Onishi in a manner that includes an alignment mechanism as suggested by Flowerdew (e.g., a dished recess or other shaped surface feature, a directional logo/marker, or both) so that the primary and secondary coils would be more readily ‘optimized’ for alignment and the inductive ‘coupling is maximized.’”). Flowerdew teaches, for example, that, with the use of a dished charging surface, the secondary unit “tends to align in one axis” and “[t]his alignment is such that the coupling between a solenoid receive coil in secondary unit 304 and the charging coils of charger 302 is maximized.” Ex. 1005, 11:25–52. Petitioner, with the supporting testimony of Dr. Woods, contends, and we agree, that a person of ordinary skill in the art “would have been sufficiently skilled to implement [the proposed] combination given the predictable techniques disclosed in each reference and the relatively advanced state of the art at the time.” Id. at 17 (citing Ex. 1003 ¶ 55). We determine that Petitioner has shown that the proposed combination teaches or suggests the subject matter of limitation 1.3 and that Petitioner has set forth adequate and persuasive reasons with rational underpinning as to why a person of ordinary skill in the art would have modified Onishi’s system to utilize an alignment mechanism. We also determine, for the reasons stated by Petitioner, that a person of ordinary skill in the art would have had a reasonable expectation of success in making the proposed combination. See Pet. 16–17; Ex. 1003 ¶ 55.” slip op. at 23
Patent outcomesUS 9,048,696 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 9,048,696 - PTAB · Nov 21, 2025 · IPR2025-00956 · APJ Ryan H Flax · IPR · Institution
The Board instituted IPR on claims 1–12 under all asserted grounds, finding a reasonable likelihood that at least one claim is unpatentable.
In the decision…Poovey, and Gracco (see Pet. 54–64 (citing, inter alia, Ex. 1002 ¶¶ 262–283)), and asserts that 35 IPR2025-00956 Patent 11,937,992 B1 based on the teachings of Poovey and Gracco, a POSA would have modified the threads of shaft 754 of fastener 750 [of Bernhard] in two respects, so that the…
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“institute trial in an inter partes review. We institute an inter partes review only if the information presented in the petition filed under 35 U.S.C. § 311, and any preliminary response filed under § 313, shows that there is a reasonable likelihood that Petitioner would prevail with respect to at least one of the claims challenged in the petition. 35 U.S.C. § 314. After reviewing the parties’ submissions in view of the existing record, we conclude that Petitioner demonstrates a reasonable likelihood it would prevail in showing that at least one challenged claim of the ’992 patent is unpatentable under the presented grounds. See Pet. Therefore, we grant institution of inter partes review. Our reasoning is discussed below. A.” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“These two proposed definitions of the ordinarily skilled artisan share many consistencies, for example, the types of degrees and experience such a person would have had, but differ in the number of years of experience. Petitioner proposes the ordinarily skilled artisan would have had at least five years of experience and Patent Owner proposes at least three years (which would necessarily include five years, too). Patent Owner also proposes that the ordinarily skilled artisan would have consulted a dentist, oral surgeon, prosthodontist, or periodontist with experience in dental implants and prosthetics. At this point, we find little meaningful difference between the two proposed definitions. In fact, neither does Patent Owner’s witness, Mr. Leinsing, who states that his “opinions would not change under either definition.” Ex. 2011 ¶ 40. Thus, at this stage, we accept and use Petitioner’s proposed definition of the ordinarily skilled artisan, which, unlike Patent Owner’s, does not implicate reliance on the knowledge of people other than the individual ordinarily skilled artisan. Petitioner’s definition appears to comport with the level of skill in the art reflected in the prior art of record and the ’992 patent. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (“the prior art itself [may] reflect[] an appropriate level” of the ordinary level of skill in the art) (quoting Litton Indus. Prods., Inc. v. Solid State Sys. Corp., 755 F.2d 158, 163 (Fed. Cir. 1985)). This parties may further developed this issue at trial, if desired. C.” slip op. at 13
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“The Board interprets claim terms in an inter partes review using the same claim construction standard that is used to construe patent claims in a civil action in federal district court. 37 C.F.R. § 42.100(b). In construing claims, district courts and the Board here, by default, give claim terms their ordinary and customary meaning, which is “the meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention.” Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc).” slip op. at 14
- Disclosure Requirements (§112) › Written description (Ariad)Written description inadequateNot entitled to earlier dateDecided for petitioner
“Here, the first claim limitation at issue is broad, i.e., different thread pattern/profile between a definite and a temporary screw, and the Specification’s and priority applications’ disclosure is narrow and specific, asymmetric buttress style threads in a temporary screw and symmetrical threads in a definite screw (are different). Any apparent predictability in or maturity of the relevant field here must be contrasted with the fact that the Specification, considering the ’992 patent itself or any of the identified priority applications, never once even discusses the (claimed) concept of specifically differing the thread style between a temporary and a definitive screw. Any differences in thread style are not called out by the disclosure, but are described and can be discerned only in relation to the respective threads’ functionality, i.e., Fig. 75’s temporary screw 190 has buttress-style threading so it can be pulled out rather than unscrewed from the abutment; Fig. 9’s definitive screw 75 has male threads that fill the female threads of the abutment 8 for a secure permanent engagement. Ex. 1001, 15:23–30, 21:25–44, 23:3–36; Ex. 1012, 97–98, Figs. 9, 75. And, although it is possible for a single disclosed species to provide written description support for a claimed genus, “a sufficient description of a genus . . . requires the disclosure of either a representative number of species falling within the scope of the genus or structural features common to the members of the genus so that one of skill in the art can ‘visualize or recognize’ the members of the genus.” Ariad, 598 F.3d at 1350; see also Synthes USA, LLC v. Spinal Kinetics, Inc., 734 F.3d 1332, 1344 (Fed. Cir. 2013). That does not appear to be the case here—the present record does not support that the described asymmetrical buttress, serrated style of different temporary screw threading (relative to that of the definitive screw and regardless of the direction of the threads for rotation) is sufficiently representative of the genus’s “different” thread patterns/profiles. See, e.g., Ex. 1006 (a buttress style thread does not function the same as a buttress reverse or 75º joint profile or rounded, or trapezoidal thread).” slip op. at 30
Claim construction§ 102 anticipation§ 103 obviousness§ 112 disclosurecites Phillips · GrahamPatents in suitUS 11,937,992
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.