- Google LLC v. Withrow Networks Inc.All claims unpatentablePTAB · Sep 25, 2026 · IPR2025-00775 · APJ Justin T Arbes · IPR · Final written decision
Claims 1–9 are unpatentable as obvious over each of the five asserted §103 grounds, including Carmel with Mattavelli and Carmel with Wang.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner argues that at the relevant time of the invention claimed in the ’849 patent (April 2005),2 a person of ordinary skill in the art would have had “at least a bachelor’s degree in computer science, computer engineering, electrical engineering, or an equivalent field requiring learning computation principles, and two years of work experience in networking or streaming media systems, particularly audio and video, over the Internet,” where “[a]dditional education could compensate for less practical experience and vice versa.” Pet. 5–6 (citing Ex. 1002 ¶¶ 18–23). In the Decision on Institution, the Board agreed with and applied Petitioner’s proposed definition. Dec. on Inst. 9–11. Patent Owner proposes a very similar definition of “a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and two to three years of experience in the design or development of (1) video processing systems, audio processing systems, and/or the equivalent; and (2) networking and communications systems, or the equivalent,” where “[a]dditional graduate education could substitute for professional experience, or significant experience in the field could substitute for formal education.” PO Resp. 23 2 Petitioner states that it “uses [the earliest possible priority date of April 18, 2005] as the priority date of the challenged claims.” Pet. 6. Patent Owner agrees that the “earliest effective filing date” of the challenged claims is April 18, 2005. PO Resp. 19. The ’849 patent is expired. See Ex. 1001, codes (63), (*); Paper 8, 33. would be the same under either level” of ordinary skill in the art. Id. Based on the full record developed during trial, including our review of the ’849 patent and the types of problems and solutions described in the ’849 patent and cited prior art, we maintain the previously adopted definition of the level of ordinary skill in the art, but remove the term “at least” to avoid unnecessary ambiguity. Our analysis herein, however, would be the same under either party’s proposed definition.” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“37 C.F.R. § 42.100(b). Petitioner states in the Petition that it “does not presently contend that any term requires express construction.” Pet. 6. Patent Owner “does not believe any terms of the ’849 [p]atent require express constructions for purposes of” this proceeding. PO Resp. 24; Sur-Reply 11. The Board did not interpret any terms in the Decision on Institution. Dec. on Inst. 8. We agree that no terms require express interpretation to determine whether Petitioner has met its burden to prove unpatentability of the challenged claims. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“Because we need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy,’ we need not construe” slip op. at 8
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“Finally, Petitioner explains in detail why and how a person of ordinary skill in the art would have had reason to combine the teachings of Carmel and Mattavelli, with a reasonable expectation of success. See Pet. 50–55. Specifically, an ordinarily skilled artisan would have modified Carmel’s system to use “Mattavelli’s CGD techniques to optimize the decoding of in more efficient network bandwidth usage and improved playback of multimedia data streams. Id. at 50, 52–53, 55. Petitioner contends that Carmel and Mattavelli are both directed to processing multimedia data playback “for the appreciation of a user,” while providing the highest perceived audio and video output quality possible in view of system constraints to ensure playback continuity. Id. at 50–51 (citing Ex. 1003, 7:35–49, 10:48–54, 11:9–18, Figs. 3D, 6B; Ex. 1004, 2309–10). Petitioner argues that Carmel and Mattavelli both pertain to compression of multimedia data using well-known coding and compression standards for video streaming. Id. at 51 (citing Ex. 1003, 7:25–26, 11:24–52; Ex. 1004, 2309–11). Petitioner further asserts that a person of ordinary skill in the art would have appreciated that Carmel and Mattavelli “complement[]” each other because Carmel addresses constraints on available network bandwidth and Mattavelli addresses limits on available processing resources at the client/multimedia player. Pet. 52 (citing Ex. 1003, code (57), 7:36–41; Ex. 1004, 2309–2312). According to Petitioner, an ordinarily skilled artisan would have been motivated to combine the complementary teachings in Carmel and Mattavelli to create a more robust streaming system that addresses both bandwidth constraints and client processing limits to provide the best possible playback experience. Id. (citing Ex. 1002 ¶¶ 212–215). Petitioner also contends that Mattavelli teaches that merely optimizing transmission bandwidth is not sufficient and is potentially harmful, which provides an express motivation to combine Carmel’s and Mattavelli’s complementary teachings to ensure that different, related links in the streaming playback chain are optimized together. Id. at 53 (citing Ex. 1002 express disclosure that would have motivated a person of ordinary skill in the art to incorporate Mattavelli’s complementary teachings regarding decoding because Carmel states that multimedia playback is achieved “preferably with only a minimal necessary transmission and decoding delay.” Id. at 53–54 (quoting Ex. 1003, 10:50–54; citing Ex. 1002 ¶ 218). Patent Owner in its Response does not dispute that Carmel and Mattavelli teach the preamble and limitations 1[a.i]–1[c.i], or that a person of ordinary skill in the art would have been motivated to combine the references’ teachings in the manner asserted by Petitioner.6 Nonetheless, the burden remains on Petitioner to demonstrate unpatentability. Dynamic Drinkware, 800 F.3d at 1378 (discussing the burden of proof in inter partes review). Having reviewed Carmel and Mattavelli, on the complete trial record, we agree with Petitioner’s analysis, as supported by the testimony of” slip op. at 22
Patent outcomesUS 10,771,849 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,771,849 - Clearwater Paper Corporation v. Graphic Packaging International LLCAll claims unpatentablePTAB · Sep 23, 2026 · IPR2025-00878 · APJ Carl M Defranco · IPR · Final written decision
Claims 1–3 and 11 are unpatentable as anticipated by Cleveland and obvious over Nakagawa and over Nakagawa combined with Tanner.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“would have at least a bachelor’s degree in mechanical or chemical engineering, materials science, polymer science, or equivalent coursework, at least a year of experience developing paper-based laminates involving the application of polymer coatings to a substrate, and the appropriate industry familiarity with biodegradability standards and degradability techniques [and] . . . [l]ess work experience may be compensated by a higher level of education, such as a master’s degree, and vice versa. Pet. 16 (citing Ex. 1003 ¶ 50). Clearwater’s definition is uncontested, and we apply that definition here, as it accords with the level of skill reflected in the asserted prior art and the problems addressed in the specification of the ’126 patent. C. Claim Construction” slip op. at 6
- Expert testimonyPetitioner expert creditedDecided for petitioner
“We have reviewed the cited testimony of Clearwater’s expert, including their calculations for arriving at a coat weight in Nakagawa that falls within the claimed range. See Ex. 1003 ¶¶ 132–33. We find that testimony, which is unrebutted, both credible and supported by the evidence of record. Thus, in light of Clearwater’s contentions, the cited portions of Nakagawa, and the unrebutted testimony of Clearwater’s expert, we are persuaded that Nakagawa discloses or otherwise suggests each and every element of claim 1. See Pet. 45–54, 60–64. Clearwater also persuades us that Cleveland discloses the additional subject matter of dependent claims 2, 3, and 11. See Pet. 64–66. Thus, we determine that Clearwater demonstrates that claims 1–3 and 11 are unpatentable as obvious over Nakagawa. F. Ground 3—Obviousness Over Nakagawa and Tanner” slip op. at 17
- Novelty / Anticipation (§102) › Prior-art status of a reference › Patents / published applications (effective date, provisional support)Reference is prior artDecided for petitioner
“qualifies as prior art under 35 U.S.C. § 102(e)(1) “based on both its provisional and non-provisional filing dates.” Inst. Dec. 4 n.5. We were persuaded by Clearwater’s proof that Cleveland’s provisional (Ex. 1006) is “virtually identical” to Cleveland itself (Ex. 1005) and that the provisional provides written description support for at least claim 1 of Cleveland. See Pet. 18–21 (citing Ex. 1006, 2–6, 9). We were also persuaded by Clearwater’s showing that the provisional provides written support for the subject matter relied upon in Cleveland. Id. at 21–40 (citing Ex. 1006, 1–9). We are still persuaded by Clearwater’s showing. Thus, we see no reason to disturb our earlier finding that Cleveland is prior art to the ’126 patent.” slip op. at 7
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“protectant layers has “a coat weight of from 5 to 30 lbs/3000 ft2.” As noted by Clearwater, Cleveland discloses a total coat weight for layers 14 and 16 as falling within the claimed range. Pet. 32–34 (citing Ex. 1005 ¶ 32). In particular, Cleveland discloses that “the coextruded layer of copolyester (irrespective of which side of the substrate the layer is disposed) is of a total coat weight of between about 10 and about 40 lb/3000 ft2 in any combination of between about 80/20 to 20/80 parts by weight of Ecoflex to Biomax,” of which “a total coat weight of 25 lb/3000 ft2 is preferred.” Ex. 1005 ¶ 32. As disclosed, Cleveland’s total coat weight range of 10–40 lb/3000 ft2 falls almost entirely within the claimed range, and the preferred total coat weight of 25 lb/3000 ft2 falls squarely within the claimed range. Thus, Cleveland satisfies claim elements [1.3.2] and [1.5.2]. See Titanium Metals Corp. v. Banner, 778 F.2d 775, 782 (Fed. Cir. 1985) (“[W]hen, as by a recitation of ranges or otherwise, a claim covers several compositions, the claim is anticipated if one of them is in the prior art.”) (citation omitted). As such, we find that Clearwater adequately demonstrates that Cleveland discloses all the elements of claim 1. 4. Dependent Claims” slip op. at 12
Patent outcomesUS 8,637,126 unpatentable§ 102 anticipation§ 103 obviousnesscites PhillipsPatents in suitUS 8,637,126 - Amazon.Com, Inc. / Amazon.Com Services LLC et al. v. Soundclear Technologies LLCAll claims unpatentablePTAB · Sep 3, 2026 · IPR2025-00673 · APJ Michael R Zecher · IPR · Final written decision
Claims 1–7 are unpatentable as obvious over the combined teachings of the asserted references, including Shin and Aoyama and Shimomura and Iwase.
RulingsFinal written decision- PTAB / AIA Trials › Motions to amend / substitute claimsOther
“1 SoundClear also filed a Contingent Motion to Amend that proposed to replace originally challenged claim 5 of the ’675 patent with proposed substitute claim 8. Paper 21. We, however, granted SoundClear’s request to withdraw its Contingent Motion to Amend and, as a result, the Contingent Motion to Amend will no longer be considered in this proceeding. Paper 30.” slip op. at 2
- Skill levelOther
“2. Level of Skill in the Art In determining whether an invention would have been obvious, we” slip op. at 21
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundMotivation not foundMixed
“combination because (1) configuring Shin’s processor 120 accordingly “would have been trivial, involving straightforward changes to enhance the processor’s approach to simplifying and abbreviating its output”; and (2) this approach was well-known as evidenced by Ha’s disclosure of replacing “team meeting” and “date” with “schedules” based on the user’s environment.6 Id. at 27–28 (first quoting Ex. 1011 ¶ 97, then quoting Ex. 1011 ¶ 98) (citing Ex. 1002 ¶ 102; Ex. 1011, Fig. 7).” slip op. at 33
- Expert testimonyPetitioner expert creditedDecided for petitioner
“4. Dr. Stern’s Testimony is Reliable In its Patent Owner Response, SoundClear contends that “Dr. Stern’s” slip op. at 125
Patent outcomesUS 11,244,675 unpatentable§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,244,675 - Amazon.Com, Inc. / Amazon.Com Services LLC et al. v. Soundclear Technologies LLCAll claims unpatentablePTAB · Jul 27, 2026 · IPR2025-00565 · APJ Michael R Zecher · IPR · Final written decision
Claims 1–5 are unpatentable because Amazon showed they are anticipated by Shin; the Board did not reach Amazon’s contingent obviousness ground over Shin.
RulingsFinal written decision- BurdenOther
“Written Decision under 35 U.S.C. § 318(a) as to the patentability of claims 1–5 of the ’337 patent. For the reasons we identify below, we hold that Amazon has demonstrated by a preponderance of the evidence that these claims are unpatentable.” slip op. at 2
- Skill levelOther
“2. Level of Skill in the Art In determining whether an invention would have been obvious, we” slip op. at 18
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“1. Principles of Law To establish anticipation, “all of the elements and limitations of the” slip op. at 17
- Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableNot shown unpatentableMixed
“1. Principles of Law To establish anticipation, “all of the elements and limitations of the” slip op. at 17
Patent outcomesUS 11,069,337 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,069,337 - Shenzhen Tuozhu Technology Co., Ltd. v. Stratasys, Inc.All claims unpatentablePTAB · Jun 9, 2026 · IPR2025-00311 · APJ Christopher M Kaiser · IPR · Final written decision
Claims 1, 3–11, and 17–22 are unpatentable as obvious over grounds using Mazumder and Mori; grounds relying on Henke fail because Henke is not analogous art.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“had a bachelor’s degree in Mechanical Engineering, Computer Engineering, Electrical Engineering, Materials Science, or a comparable field and at least two years of experience related to 3D printers including remote control of rapid fabrication systems.” Pet. 6 (citing Ex. 1003 ¶¶ 40–42). Petitioner also argues that “[a]dditional years of experience could substitute for an advanced-level degree (and vice versa).” Id. Patent Owner proposes a slightly different level of skill, arguing that a person of ordinary skill in the art “would have had a bachelor’s degree in Mechanical Engineering, Computer Engineering, Electrical Engineering, Materials Science, or a comparable field and at least two years of experience related to 3D printing, with additional experience potentially being a substitute for a formal degree or training (and vice versa).” PO Resp. 11–12. Neither party explains why the outcome of this case would be affected by the adoption of either of the proffered definitions of a person of ordinary skill in the art. We adopt Petitioner’s assessment of the level of ordinary skill in the art, as it appears consistent with the ’324 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“There is also evidence that supports Petitioner’s proposed construction, under which a user interface may display both the image and the projection if it displays them at different times. This evidence includes statements in the specification that describe displaying an image “instead” of “a rendering of a three-dimensional model” and that describe displaying a “video image and/or model projection” rather than merely a video image and a model projection. Ex. 1001, 22:43–53, 24:52–55, Figs. 5, 7. It also includes arguments in the prosecution history distinguishing Taminger on the basis of failure of disclose any display of both an image and a projection at all, rather than on the basis of failure to disclose simultaneous display of both visualizations. Ex. 1002, 160, 161. Based on our review of all the probative evidence, we find that the preponderance of the evidence supports Petitioner’s view, so we construe the challenged claims as not requiring simultaneous display of the image and the projection.” slip op. at 15
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“With the problem solved by the ’324 patent defined as monitoring automated three-dimensional fabrication processes, we find that Mori is at least reasonably pertinent to the problem. Mori discloses “[a] machining status monitoring apparatus.” Ex. 1005, code (57), ¶ 43. That apparatus uses “actual CCD cameras . . . to image the workpiece.” Id. ¶ 49. It also has a “virtual image generating section” with “virtual CCD cameras” having “view points” that “match the view points of the actual CCD cameras.” Id. ¶¶ 59, 61, 62. This disclosure relates quite closely to monitoring an automated three-dimensional fabrication process and thus is at least reasonably pertinent to solving that problem. d) Conclusion For the reasons discussed above, Mori is both in the same field as the ’324 patent and at least reasonably pertinent to the problem solved by the ’324 patent. Accordingly, it is analogous art to the ’324 patent.” slip op. at 21
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner
“Regarding combining the teachings of Mazumder with those of Mori, the evidence of record shows that the print head of Mazumder’s three-dimensional printer could obscure portions of the actual camera’s view of the object being printed and that displaying Mori’s virtual image of the object in addition to Mazumder’s actual image of the object “would have allowed the user to of the remote computer to monitor the progress of the object even when the actual view of the object is partially or totally obscured.” Ex. 1003 ¶ 86. c) Conclusion Regarding Claim 1 For the reasons discussed above, the preponderance of the evidence shows that claim 1 would have been obvious over the combination of Mazumder and Mori.” slip op. at 26
Patent outcomesUS 8,562,324 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 8,562,324 - Shenzhen Tuozhu Technology Co. Ltd. v. Stratasys, Inc.All claims unpatentablePTAB · Jun 3, 2026 · IPR2025-00257 · APJ Lilan Ren · IPR · Final written decision
Claims 1–15 are unpatentable because Petitioner proved by a preponderance of the evidence that the asserted § 103 grounds render them unpatentable.
RulingsFinal written decision- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“proceeding, we determine Petitioner has proven by a preponderance of the evidence that each of claims 1–15 of the ’660 patent is unpatentable.” slip op. at 85
Patent outcomesUS 9,592,660 unpatentable§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 9,592,660 - Mediatek Inc. v. Parkervision, Inc.All claims unpatentablePTAB · May 22, 2026 · IPR2024-00796 · APJ Iftikhar Ahmed · IPR · Final written decision
Claims 1–20 are unpatentable as obvious over Nevo and Avitabile, Young and Estabrook, and Young, Estabrook-1988, and Estabrook-1989.
RulingsFinal written decision- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“Network LLC, 929 F.3d 1350, 1357 (Fed. Cir. 2019). On its face, the language “energy transfer signal” does not specify any restrictions on the type of system in which it is utilized, nor its characteristics. In the context of claims 1 and 11, the “energy transfer signal” is the basis on which the “switch” operates, so as to “sub-sample and transfer energy from a first electromagnetic (EM) signal.” Ex. 1001, 50:63–65, 51:56–58. Accordingly, based on the claim language, the term “energy transfer signal” need only be a signal for operating a switch to sub-sample and transfer energy from an electromagnetic signal. That is its plain and ordinary meaning.” slip op. at 15
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“’686 patent broadly includes knowledge and experience as to RF circuit design. See supra § III.B. Petitioner contends that “Nevo’s transceivers [102a/102b] are for Bluetooth and IEEE 802.11,” and that a person of ordinary skill in the art would have understood that both protocols “required down-conversion in their receivers to obtain a baseband signal.” Id. at 35 (citing Ex. 1004, 4:45–50; Ex. 1002 ¶ 118). Nevo’s disclosure would have motivated a person of ordinary skill in the art to look to Avitabile, which provides the circuit level detail for down-converters. See Ex. 1006, Abstract. Avitabile specifically provides circuitry for down-conversion in the s-band frequency range, which is in the range of Bluetooth and IEEE 802.11 (2.4 GHz). Id. at Abstract, Figs. 6, 7. Accordingly, we determine a person of ordinary skill in the art would have been motivated to look to down-converters in the range of frequency needed, and would have been motivated to combine Avitabile’s teachings with those of Nevo, with a reasonable expectation of success.” slip op. at 55
- Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner
Patent outcomesUS 7,483,686 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 7,483,686 - Mediatek Inc. v. Parkervision, Inc.All claims unpatentablePTAB · Mar 31, 2026 · IPR2025-00030 · APJ Barry L Grossman · IPR · Final written decision
Claims 1–20 are unpatentable as obvious over the combinations in Grounds 1A–1C and 2A–2C.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“stated by Patent Owner. Ex. 2001 ¶ 25. This proposed level of skill is nearly identical to that proposed by Petitioner. Unlike Dr. Larson, however, Dr. Ricketts states his “opinion,” without stating the facts, data, or factors that he considered in reaching his opinion. Accordingly, we give his testimony little probative weight. 37 C.F.R. § 42,65(a) (“Expert testimony that does not disclose the underlying facts or data on which the opinion is based is entitled to little or no weight.”). For purposes of this Decision, based on the prior art, the sophistication of the disclosed technology in the ’593 patent, and Dr. Larson’s testimony, we adopt Petitioner’s definition of the level of ordinary skill, which is that a person of ordinary skill in the art would have had: at least a bachelor’s degree in electrical engineering or a related subject and two or more years of experience in the field of RF circuit design and/or power supplies for RF circuits, or at least five years of work experience and training in the design and development of RF circuits and/or power supplies for RF circuits. Less work experience may be compensated by a higher level of education, such as a master’s degree.” slip op. at 15
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed petitioner constructionDecided for petitioner
“on the construction of the claim term “power efficiency,” we agree with Petitioner and its declarant, Dr. Larson, that a person of ordinary skill (i.e., a degreed engineer with two or more years of experience in the field of RF circuit design and/or power supplies for RF circuits) would have understood that to determine the power efficiency of a circuit, one would measure the components or characteristics of power, such as voltage and current, to determine the output power of the power supply compared to its input power. Based on our construction of the claim term “power efficiency,” we also note that the claims only require performing a bypass function when the efficiency threshold is exceeded. The claims do not require a power efficiency ratio to be measured or calculated. Thus, we decline Patent Owner’s attempt to limit the claim term “power efficiency” to a ratio.” slip op. at 30
- Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableMotivation foundUnpatentable
“Section II.D.2 of this decision), Hau teaches a bypass controller 74 (purple) which receives a signal Pdet from a power detector (pink) and activates a bypass switch 72 (purple) when the signal Pdet exceeds a predetermined threshold (in response to a power efficiency of the power supply exceeding a predetermined threshold). Id. at 28 (citing Ex. 1007, 5:43–51, 6:57–7:20). According to Petitioner Hau discloses that the strength of the signal Pdet, the power output of the amplifier PA1, and the supply voltage Vcc2 are all proportional. Id. at 29 (citing Ex. 1007, 6:22–44; Ex. 1003 ¶¶ 122–123. Petitioner concludes, therefore, that Pdet is an indicator of the power output by the DC-DC buck regulator at Vcc2. Id. Petitioner also concludes that because input power is supplied to the DC-DC buck regulator from a fixed voltage, Pdet is also an indicator of the power efficiency of the DC-DC buck regulator because higher power indicated at Pdet indicates greater efficiency relative to the fixed input power. Pet.29 (citing Ex. 1003 ¶ 123). Dr. Larson’s testimony supports Petitioner’s conclusions. Petitioner also asserts: when Pdet exceeds the predetermined threshold, Hau’s bypass controller 74 activates bypass switch 72 and deactivates the DC- DC converter (which is a PWM switching device in the combination of Hau and Yoshida) (deactivates the switching device) to pass the input voltage directly to the output voltage Vcc2 (passes the input voltage to the output voltage node). Pet. 30 (citing Ex. 1007, 5:44-51, 6:61, 66; Ex. 1003 ¶¶ 125-126).” slip op. at 39
- Obviousness (§103) › Motivation to combine / reasonable expectation of success › HindsightUnpatentableMotivation foundUnpatentable
“According to Petitioner, it would have been obvious to a person of ordinary skill “to set Hau’s predetermined threshold to correspond to the point at which a fixed power supply (e.g., the bypass pathway of Hau) becomes more efficient than the down-converted power supply, as taught by Sahu.” Pet. 50–51 (citing Ex. 1007, 6:63–66; Ex. 1003 ¶¶ 166–167). Petitioner also asserts a person of ordinary skill “would have recognized that Sahu’s efficiency graph shows performance for a particular modulation scheme”, and that the resulting efficiency of the system using that modulation scheme “correlates with the efficiency of the communication waveform in that scheme (based on a communication waveform efficiency).” Id. at 51 (citing Ex. 1003 ¶ 168). Petitioner concludes that a person of ordinary skill “would have understood and found it obvious that basing the predetermined threshold of Hau on the point where a fixed power supply becomes more efficient as taught by Sahu is programming the threshold voltage based on a communication waveform efficiency.” Id. at 51 (citing Ex. 1003 ¶ 168). We find Petitioner’s contentions persuasive. Patent Owner asserts it is “hindsight” to rely on Sahu. PO Resp. 51 (a person of ordinary skill “would not have equated Sahu’s fixed-supply system with Hau’s bypass pathway without the benefit of hindsight”). According to Patent Owner, “Petitioner used the disclosures in the ’593 patent as a road map for reasons to combine Sahu and Hau/Yoshida.” Id. (citing Ex. 2001, ¶¶ 174–75). Patent Owner also asserts a person of ordinary skill “would have recognized that Figure 8(a) of Sahu “relates to specific devices that were tested in Sahu.” Id. at 50. We find these assertions unpersuasive. We have discussed above the” slip op. at 57
Patent outcomesUS 8,498,593 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 8,498,593 - Valve Corporation v. Immersion CorporationAll claims unpatentablePTAB · Mar 23, 2026 · IPR2024-00582 · APJ Christopher L Ogden · IPR · Final written decision
Claims 1–6, 14–16, and 19 are unpatentable based on anticipation by or obviousness over Pratt, and obviousness over Pratt–Ku, Ku, or Ku–Jiang.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“The parties agree that formal education could substitute for practical experience, and vice versa. Pet. 6, PO Resp. 18. The parties’ proposed levels of ordinary skill appear to be substantially similar, supported by testimonial evidence, and consistent with the asserted prior art and the types of problems and solutions identified in the ’738 patent. See, e.g., Ex. 1001, 1:6–61. Although we discern no difference in the outcome of this decision from choosing one over the other, we adopt Petitioner’s proposed level of skill for this decision. The outcome of our decision would be the same under Patent Owner’s proposal.” slip op. at 7
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“We find insufficient support in the specification or prosecution history to narrow the term “haptic effect” to only one that has not been modified or combined with another haptic effect. The ’738 patent still refers to combined or modified haptic effects as a “haptic effect.” Ex. 1001, 11:35–38 (“a haptic effect may further be modified or combined with another haptic effect” and “the haptic effect can include one or more haptic effects”). We also find no support for importing into the construction of “haptic effect” the ’738 patent’s example in which a haptic effect can be “based on the proximity signal and the touch sensor signal.” That is already an explicit claim limitation. Id. at 14:19–20 (“generate a haptic output signal based at least in part on the first [proximity] and second [touch] sensor signals”). Including that limitation as part of the construction of “haptic effect” would render the limitation superfluous. See Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1237 (Fed. Cir. 2016) (“The Board was correct to not include in its construction of ‘menu’ features of menus that are expressly recited in the claims . . . . Construing a claim term to include features of that term already recited in the claims would make those expressly recited features redundant.”). We also disagree with Patent Owner that the ’738 patent’s references to haptic effects modified or combined with other haptic effects are unclaimed embodiments. The ’738 patent discloses that a proximity-based haptic effect may be combined with a touch-based haptic effect, such as when “a particular haptic effect associated with a particular control on a user interface element [is] further . . . modified or combined with another haptic effect based on the proximity sensor signal,” or when “the haptic effect [to be output by the processor] . . . include[s] a haptic effect meant to confirm ‘pushing’ on a virtual button.” Ex. 1001, 11:32–40. These examples are consistent with the claim language and we find no credible evidence in the record that these embodiments are intended to be excluded from the claimed invention. Thus, we agree with Petitioner that it would be incorrect to construe the term “haptic effect” to include the extraneous limitations Patent Owner proposes. We also agree with Petitioner that a person of ordinary skill in the art reading the ’738 patent disclosure would have understood that a combined or modified haptic effect is still a haptic effect.” slip op. at 11
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“To show anticipation under § 102, a petitioner must locate every element in a claim, arranged as recited in the claim, in a single prior art reference. See Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359, 1369 (Fed. Cir. 2008). The limitations may be present in the reference “either explicitly or inherently.” In re Schreiber, 128 F.3d 1473, 1477 (Fed. Cir. 1997). In making this determination, we consider the reference “together with the knowledge of one of ordinary skill in the pertinent art.” In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994) (citing In re Samour, 571 F.2d 559, 562 (CCPA 1978)).” slip op. at 13
- Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableMotivation foundUnpatentable
“We find Petitioner’s arguments persuasive and disagree with Patent Owner’s arguments to the contrary. Ku discloses summing two overlapping vibration signals, one “based at least in part on” data from a proximity sensor and another “based at least in part on” data from a touch sensor. Ex. 1008, Fig. 12 (items 705, 710, and 715). The summed signal 715 is the basis for generating what the user would perceive as a single haptic effect. See Ex. 1004 ¶ 210–212. This meets limitation 1F. We agree with Petitioner’s argument as to why there would have been a motivation to modify Pratt to include Ku’s teachings. Petitioner’s argument is not merely that Pratt was ready for improvement; Petitioner persuasively argues that a person of ordinary skill in the art would have had reason to add Ku’s method for confirming that the user has touched the intended icon to Pratt’s system. Both Pratt and Ku already disclose using both proximity and touch data in generating a haptic effect, and based on the evidence of record, we are of the view that combining the two teachings would not have been uniquely challenging or otherwise beyond the level of ordinary skill in the art. See Leapfrog Enters., Inc. v. Fisher-Price, Inc., 485 F.3d 1157, 1162 (Fed. Cir. 2007) (“Leapfrog presents no evidence that the inclusion of a reader in [electronic children's toys] was uniquely challenging or difficult to one of ordinary skill in the art.” (citing KSR, 550 U.S. at 419–420))” slip op. at 32
Patent outcomesUS 11,175,738 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 11,175,738 - Dr. Squatch, LLC v. The Procter & Gamble CompanyAll claims unpatentablePTAB · Jan 28, 2026 · IPR2024-01174 · APJ Susan L C Mitchell · IPR · Final written decision
Claims 1–8 and 10–23 are unpatentable: the Board found claims 1–15 anticipated or obvious over the asserted grounds and claims 16–23 obvious over the Native combination.
RulingsFinal written decision- Expert testimonyPetitioner expert creditedPatent owner expert discountedOther
“argument that the prior art fails to enable a stable deodorant stick. Rather, we are persuaded by Petitioner that Lesniak sufficiently teaches compositions with the relevant ingredients and achieves stable compositions through the use of a second wax having a melting point of 73 to 90° C. Reply 6–7 (citing Ex. 1003, 1:39–54). For example, Lesniak’s compositions (nos. 8 and 11) that used such a second wax, namely CastorWax MP80, are disclosed as sufficiently stable. Ex. 1003, Table 2. Here, we further credit the testimony of Dr. Michniak-Kohn that Lesniak teaches how to make stable compositions by including a secondary wax, such as castor wax, with a sufficiently high melting point. Ex. 1003, 1:39-54, 5:23-32, Table 2. Both of the compositions (nos. 8 and 11) tested by Lesniak that had such a wax passed the stability tests. Id. Ex. 1086 ¶ 7; see also Reply 6 (“Lesniak overcame any stability issues, as it expressly discloses compositions that are ‘physically stable at high and low temperatures.’”) (citing Ex. 1003, 5:23–32).” slip op. at 22
- Skill levelSkill level petitioner adoptedOther
“Petitioner proposes that a person of ordinary skill in the art (“POSA” or “POSITA”) at the time of the invention “would have (1) at least a B.S. or equivalent degree; and (2) at least two years of experience in cosmetics formulations.” Pet. 17 (citing Ex. 1002 ¶¶ 27–29). Patent Owner does not dispute Petitioner’s proposal about the POSA’s qualifications at this stage of the proceeding. PO Resp. 10. For this Decision, we adopt and apply Petitioner’s proposal above, which does not appear to be inconsistent with the level of skill reflected in the asserted prior art.” slip op. at 9
- Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble limitingDecided for patent owner
“Patent Owner asserts that the preamble of independent claim 1, 16, and 20 reciting “a deodorant stick” is limiting” as it provides antecedent basis for the recitation of “said deodorant stick being free of an aluminum salt” for each independent claim. PO Resp. 7–10. Patent Owner also points to dependent claims 6–9 as relying on the preamble reciting “a deodorant stick” as antecedent basis for claim elements. Id. at 9. We agree. Petitioner does not provide argument to the contrary. See, e.g., Pet. 19 (arguing that Lesniak discloses a deodorant stick in the form of an antiperspirant stick). We determine that no express construction of any claim term is necessary to determine whether to institute inter partes review. 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))). To the extent further discussion of the meaning any claim term is necessary to our decision, we provide that discussion below in our analysis of the asserted grounds of unpatentability.” slip op. at 8
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“We find that the evidence of record fails to support Patent Owner’s argument that the prior art fails to enable a stable deodorant stick. Rather, we are persuaded by Petitioner that Lesniak sufficiently teaches compositions with the relevant ingredients and achieves stable compositions through the use of a second wax having a melting point of 73 to 90° C. Reply 6–7 (citing Ex. 1003, 1:39–54). For example, Lesniak’s compositions (nos. 8 and 11) that used such a second wax, namely CastorWax MP80, are disclosed as sufficiently stable. Ex. 1003, Table 2. Here, we further credit the testimony of Dr. Michniak-Kohn that Lesniak teaches how to make stable compositions by including a secondary wax, such as castor wax, with a sufficiently high melting point. Ex. 1003, 1:39-54, 5:23-32, Table 2. Both of the compositions (nos. 8 and 11) tested by Lesniak that had such a wax passed the stability tests. Id. Ex. 1086 ¶ 7; see also Reply 6 (“Lesniak overcame any stability issues, as it expressly discloses compositions that are ‘physically stable at high and low temperatures.’”) (citing Ex. 1003, 5:23–32). Having considered the parties’ positions and evidence of record, summarized above, we determine that Lesniak provides sufficient disclosure to enable a person of ordinary skill in the art to formulate deodorant stick within the parameters of claim 1. Therefore, for the reasons discussed above, we conclude that Petitioner has proved by a preponderance of evidence that Lesniak anticipates claim 1.” slip op. at 22
Patent outcomesUS 11,497,706 unpatentableClaim construction§ 102 anticipation§ 103 obviousness§ 112 disclosurecites KSR · GrahamPatents in suitUS 11,497,706
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.