- PTAB · Oct 29, 2025 · IPR2025-00918 · APJ Avelyn M Ross · IPR · Institution
The Board instituted inter partes review of claims 1–11 on all asserted grounds and granted Canadian Solar’s motion for joinder in IPR2025-00007.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“We instituted review of claims 1–11 of the ’104 patent in IPR2025-00007 after a review of all arguments and evidence presented by the parties, including Patent Owner’s arguments in its preliminary response. For the reasons discussed in the Institution Decision in IPR2025-00007, we determine that Petitioner demonstrates a reasonable likelihood of showing at least one claim of the ’104 patent is unpatentable. Thus, we find that the Petition warrants institution of inter partes review on all claims and grounds set forth in the Petition.” slip op. at 11
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Patent Owner did not file an opposition to Petitioner’s Motion for Joinder. Upon consideration of Petitioner’s arguments, we are persuaded that it is appropriate under these circumstances to join Petitioner to the proceeding in IPR2025-00007. Petitioner’s agreement to accept an “understudy” role and to not actively participate in IPR2025-00007 unless the current petitioner ceases to participate will limit any potential impact on the trial schedule and will avoid increasing the costs or complexity of the proceeding. Therefore, joinder of 8 Available at https://www.uspto.gov/TrialPracticeGuideConsolidated. Petitioner to IPR2025-00007 will further the goals of a just, speedy, and inexpensive resolution of Petitioner’s challenge. 37 C.F.R. § 42.1(b).” slip op. at 12
- Skill levelSkill level petitioner adoptedDecided for petitioner
“In light of the record before us, and for purposes of this Decision, we adopt Petitioner’s proposal regarding the level of ordinary skill in the art. Based on our review of the ’104 patent and the prior art of record, we determine that the definition offered by Petitioner comports with the qualifications a person would have needed to understand the ’104 patent and the prior art. We will make any final determination pertaining to the level of ordinary skill in the art, however, on the full trial record.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“For purposes of this Decision, we need not expressly construe any claim terms. See Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (holding that “only those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy”); see also Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs. in the context of an inter partes review).” slip op. at 11
Claim constructioncites Phillips · KSR · GrahamPatents in suitUS 9,722,104 - PTAB · Oct 29, 2025 · IPR2025-00917 · APJ Debra L Dennett · IPR · Institution
The Board instituted IPR on claims 1–17 on all asserted grounds, finding a reasonable likelihood that at least one challenged claim is unpatentable, and granted Canadian Solar’s motion for joinder.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“We instituted review of claims 1–17 of the ’009 patent in IPR2025-00006 after a review of all arguments and evidence presented by the parties, including Patent Owner’s arguments in its preliminary response. For the reasons discussed in the Institution Decision in IPR2025-00006, we determine that Petitioner demonstrates a reasonable likelihood of showing at least one claim of the ’009 patent is unpatentable. Thus, we find that the Petition warrants institution of inter partes review on all claims and grounds set forth in the Petition.” slip op. at 11
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Patent Owner did not file an opposition to Petitioner’s Motion for Joinder. Upon consideration of Petitioner’s arguments, we are persuaded that it is appropriate under these circumstances to join Petitioner to the proceeding in IPR2025-00006. Petitioner’s agreement to accept an “understudy” role and to not 8 Available at https://www.uspto.gov/TrialPracticeGuideConsolidated. actively participate in IPR2025-00006 unless the current petitioner ceases to participate will limit any potential impact on the trial schedule and will avoid increasing the costs or complexity of the proceeding. Therefore, joinder of Petitioner to IPR2025-00006 will further the goals of a just, speedy, and inexpensive resolution of Petitioner’s challenge. 37 C.F.R. § 42.1(b).” slip op. at 12
- Skill levelSkill level petitioner adoptedOther
“Petitioner contends that a person of ordinary skill in the art would have been someone with an advanced degree involving the disciplines of electrical engineering, applied physics, chemistry, or materials science, and at least two years of experience designing, developing, or researching in the field. Alternatively, that person would have had a bachelor’s degree in electrical engineering, applied physics, or materials science, and at least three years of experience designing, developing, or researching in the field. Pet. 5 (citing Ex. 1003 ¶ 49). In light of the record before us, and for purposes of this Decision, we adopt Petitioner’s proposal regarding the level of ordinary skill in the art. Based on our review of the ’009 patent and the prior art of record, we determine that the definition offered by Petitioner comports with the qualifications a person would have needed to understand the ’009 patent and the prior art. We will make any final determination pertaining to the level of ordinary skill in the art, however, on the full trial record.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner contends that “[n]o claim construction is necessary to resolve this Petition.” Pet. 25. For purposes of this Decision, we need not expressly construe any claim terms. See Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (holding that “only those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy”); see also Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs. in the context of an inter partes review).” slip op. at 11
Claim constructioncites Phillips · KSR · GrahamPatents in suitUS 10,230,009 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Molecular Rebar Design, LLCInstitutedPTAB · Jul 17, 2025 · IPR2025-00359 · APJ Avelyn M Ross · IPR · Institution
The Board instituted review of claims 1–4 and 7–17 on all petition grounds and granted Samsung’s unopposed motion for joinder in IPR2024-01013.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“We instituted review of claims 1–4 and 7–18 of the ’483 patent in IPR2024- 01013 after a review of all arguments and evidence presented by the parties, including Patent Owner’s arguments in its preliminary response. For the reasons discussed in the Institution Decision in IPR2024-01013, we determine that Petitioner demonstrates a reasonable likelihood of showing at least one claim of the ’483 patent is unpatentable. Thus, we find that the Petition warrants institution of inter partes review on all claims and grounds set forth in the Petition.” slip op. at 8
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Upon consideration of Petitioner’s arguments, we are persuaded that it is appropriate under these circumstances to join Petitioner to the proceeding in IPR2024-01013. Petitioner’s agreement to accept an “understudy” role and to not actively participate in IPR2024-01013 unless the current petitioner ceases to participate will limit any potential impact on the trial schedule and will avoid increasing the costs or complexity of the proceeding. Therefore, joinder of Petitioner to IPR2025-00359 will further the goals of a just, speedy, and inexpensive resolution of Petitioner’s challenge. 37 C.F.R. § 42.1(b).” slip op. at 10
Nonecites Phillips · KSR · GrahamPatents in suitUS 10,153,483 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Molecular Rebar Design, LLCInstitutedPTAB · Jul 17, 2025 · IPR2025-00358 · APJ Julia Heaney · IPR · Institution
The Board instituted review of claims 1–16 on all petition grounds and granted Samsung’s motion to join IPR2024-01012 as an understudy petitioner.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“A. Whether the Petition Warrants Institution As we note above, the Petition challenges the same claims on the same grounds of unpatentability, and relies on the same evidence, including the same declarant testimony, as presented in the 1012 IPR. Pet. 1; Mot. 6– 7. In other words, the Petition is virtually identical to the petition filed in the 1012 IPR. We incorporate our analysis from the 1012 IPR regarding the asserted grounds of unpatentability and determine that Petitioner has demonstrated sufficiently under 35 U.S.C. § 315(c) that institution of an inter partes review is warranted under 35 U.S.C. § 314(a).” slip op. at 4
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Based on the facts and circumstances discussed above, we determine Petitioner has established good cause for joining the 1012 IPR. Specifically, we find that joining Petitioner to the 1012 IPR is unlikely to require any delay or modification to the scheduling order already in place for the 1012 IPR. We also determine that Patent Owner will not be prejudiced unduly by the joinder of this proceeding. Thus, we determine that granting the Motion for Joinder under these circumstances would help “secure the just, speedy, and inexpensive resolution” of these proceedings. See 37 C.F.R. § 42.1(b). For the above reasons, we grant Petitioner’s Motion for Joinder and join Petitioner as a party to the 1012 IPR.” slip op. at 6
NonePatents in suitUS 10,608,282 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Molecular Rebar Design, LLCInstitutedPTAB · Jul 17, 2025 · IPR2025-00355 · APJ Julia Heaney · IPR · Institution
The Board instituted inter partes review of claims 1–23 on the petition’s grounds and granted Samsung’s motion to join the LGES IPR in an understudy role.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“A. Whether the Petition Warrants Institution As we note above, the Petition challenges the same claims on the same grounds of unpatentability, and relies on the same evidence, including the same declarant testimony, as presented in the 1005 IPR. Pet. 1; Mot. 5. In other words, the Petition is virtually identical to the petition filed in the 1005 IPR. We incorporate our analysis from the 1005 IPR regarding the asserted grounds of unpatentability and determine that Petitioner has demonstrated sufficiently under 35 U.S.C. § 315(c) that institution of an inter partes review is warranted under 35 U.S.C. § 314(a).” slip op. at 4
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Based on the facts and circumstances discussed above, we determine Petitioner has established good cause for joining the 1005 IPR. Specifically, we find that joining Petitioner to the 1005 IPR is unlikely to require any delay or modification to the scheduling order already in place for the 1005 IPR. We also determine that Patent Owner will not be prejudiced unduly by the joinder of this proceeding. Thus, we determine that granting the Motion for Joinder under these circumstances would help “secure the just, speedy, and inexpensive resolution” of these proceedings. See 37 C.F.R. § 42.1(b). For the above reasons, we grant Petitioner’s Motion for Joinder and join Petitioner as a party to the 1005 IPR.” slip op. at 6
NonePatents in suitUS 9,636,649 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Molecular Rebar Design, LLCInstitutedPTAB · Jul 17, 2025 · IPR2025-00356 · APJ Grace Karaffa Obermann · IPR · Institution
The Board instituted review of claims 1–8 on all petition grounds and granted Samsung’s unopposed motion to join IPR2024-01006.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“We agree with the parties that the Samsung Petition “involves the same patent, challenges the same claims, relies on the same expert declaration, and is based on the same grounds and combinations of prior art.” Id. (Patent Owner’s admission); see Mot. 3 (Petitioner, averring that the Samsung Petition and the Petition filed in IPR1006 are “substantively identical”). Under these circumstances, our reasons for instituting review based on LG Energy Solution’s Petition apply with equal force to the “substantively identical” Samsung Petition. Id. Accordingly, for the same reasons set forth in the Institution Decision filed in IPR1006, we institute review on all claims and all grounds asserted in the Samsung Petition. See generally IPR1006, Paper 8 (Institution Decision in IPR1006).” slip op. at 3
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“(1) the Motion for Joinder is timely, having been “filed within one month of the institution decision” in IPR1006; (2) the Samsung Petition “is substantially identical to the” Petition filed in IPR1006; (3) “joinder will have minimal, if any, impact on the trial schedule, as all issues are substantively identical”; (4) Petitioner agrees to “accept an ‘understudy role’” in the joined proceeding, unless LG Energy Solution, Ltd. “is terminated from” IPR1006; and (4) joinder will simplify “briefing and discovery” as all issues will be resolved “in a single proceeding.” Mot. 3–4. Patent Owner contests none of those facts. To the contrary, Patent Owner does “not oppose” the Motion for Joinder and “fully expects this proceeding to be joined with” IPR1006. Waiver 1. Having considered Petitioner’s Motion for Joinder, as well as Patent Owner’s Waiver, we determine that joinder of the instant proceeding with IPR1006 is appropriate. Accordingly, we grant Petitioner’s unopposed Motion for Joinder, subject to the requirements set forth in the Order below.” slip op. at 4
NonePatents in suitUS 8,808,909 - Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Molecular Rebar Design, LLCInstitutedPTAB · Jul 17, 2025 · IPR2025-00357 · APJ Grace Karaffa Obermann · IPR · Institution
The Board instituted review of claims 1–5 on all grounds in the Petition and granted Samsung’s unopposed motion to join IPR2024-01011.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“We agree with the parties that the Samsung Petition “involves the same patent, challenges the same claims, relies on the same expert declaration, and is based on the same grounds and combinations of prior art.” Id. (Patent Owner’s admission); see Mot. 3 (Petitioner, averring that the Samsung Petition and the Petition filed in IPR1011 are “substantively identical”). Under these circumstances, our reasons for instituting review based on LG Energy Solution’s Petition apply with equal force to the “substantively identical” Samsung Petition. Id. Accordingly, for the same reasons set forth in the Institution Decision filed in IPR1011, we institute review on all claims and all grounds asserted in the Samsung Petition. See generally IPR1011, Paper 9 (Institution Decision in IPR1011).” slip op. at 3
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Having considered Petitioner’s Motion for Joinder, as well as Patent Owner’s Waiver, we determine that joinder of the instant proceeding with IPR1011 is appropriate. Accordingly, we grant Petitioner’s unopposed Motion for Joinder, subject to the requirements set forth in the Order below.” slip op. at 4
NonePatents in suitUS 8,968,924 - PTAB · May 6, 2025 · IPR2025-00187 · APJ Debra L Dennett · IPR · Institution
The Board instituted review of claims 1–17 on all petition grounds and granted Mundra and Adani’s motion to join IPR2025-00006.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“We instituted review of claims 1–17 of the ’009 patent in IPR2025-00006 after a review of all arguments and evidence presented by the parties, including Patent Owner’s arguments in its preliminary response. For the reasons discussed in the Institution Decision in IPR2025-00006, we determine that Petitioner demonstrates a reasonable likelihood of showing at least one claim of the ’009 patent is unpatentable. Thus, we find that the Petition warrants institution of inter partes review on all claims and grounds set forth in the Petition.” slip op. at 10
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“Petitioner contends that no new grounds of unpatentability are raised in the Petition. Mot. for Joinder 3–4. Petitioner further agrees to an “understudy” role in which it will not seek additional depositions or deposition time, and “will assume the primary role only if Runergy ceases to participate in the Runergy IPR.” Id. at 1, 5–6. And, argues that “[b]ecause . . . [the] Petition presents the identical grounds for the challenged claims and the same evidence, there are no new issues 8 Available at https://www.uspto.gov/TrialPracticeGuideConsolidated. for Patent Owner to address” and “joinder with the Runergy IPR will not unduly burden or negatively impact the schedule in that proceeding in any way.” Id. at 5; see also id. at 6 (“briefing and discovery will be simplified because Patent Owner can maintain its current trial schedule and avoid duplicative efforts”.” slip op. at 11
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner contends that a person of ordinary skill in the art would have been someone with an advanced degree involving the disciplines of electrical engineering, applied physics, chemistry, or materials science, and at least two years of experience designing, developing, or researching in the field. Alternatively, that person would have had a bachelor’s degree in electrical engineering, applied physics, or materials science, and at least three years of experience designing, developing, or researching in the field. Pet. 4–5 (citing Ex. 1003 ¶ 49). Patent Owner does not address the level of ordinary skill in the art at this stage of the proceeding. See generally Prelim. Resp. In light of the record before us, and for purposes of this Decision, we adopt Petitioner’s proposal regarding the level of ordinary skill in the art. Based on our review of the ’009 patent and the prior art of record, we determine that the definition offered by Petitioner comports with the qualifications a person would have needed to understand the ’009 patent and the prior art. We will make any final determination pertaining to the level of ordinary skill in the art, however, on the full trial record.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Petitioner contends that “[n]o claim construction is believed to be necessary to resolve this Petition.” Pet. 25. And, Patent Owner does not address claim construction at this stage of the proceeding. See generally Prelim. Resp. For purposes of this Decision, we need not expressly construe any claim terms. See Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (holding that “only those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy”); see also Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs. in the context of an inter partes review).” slip op. at 10
Claim constructioncites Phillips · KSR · GrahamPatents in suitUS 10,230,009 - PTAB · May 6, 2025 · IPR2025-00186 · APJ Avelyn M Ross · IPR · Institution
The Board instituted IPR on claims 1–11 on all petition grounds and granted Mundra and Adani’s motion to join IPR2025-00007.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“after a review of all arguments and evidence presented by the parties, including Patent Owner’s arguments in its preliminary response. For the reasons discussed in the Institution Decision in IPR2025-00007, we determine that Petitioner demonstrates a reasonable likelihood of showing at least one claim of the ’104 patent is unpatentable. Thus, we find that the Petition warrants institution of inter partes review on all claims and grounds set forth in the Petition.” slip op. at 11
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“In considering a motion for joinder, and whether such joinder is appropriate, the Board may consider “whether a new ground of unpatentability is raised in the second petition, how the cost and schedule of the first proceeding will be impacted if joinder is granted, and whether granting joinder will add to the complexity of briefing and/or discovery.” Patent Trial and Appeal Board Consolidated Trial Practice Guide November 20198 at 76 (citing Kyocera Corp. v. SoftView LLC, IPR2013-00004, Paper 15 at 4 (PTAB Apr. 24, 2013)).” slip op. at 11
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner contends that a person of ordinary skill in the art would have been someone with an advanced degree involving the disciplines of electrical engineering, applied physics, chemistry, or materials science, and at least two years of experience designing, developing, or researching in the field. Alternatively, that person would have had a bachelor’s degree in electrical engineering, applied physics, or materials science, and at least three years of experience designing, developing, or researching in the field.” slip op. at 9
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“For purposes of this Decision, we need not expressly construe any claim terms. See Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (holding that “only those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy”); see also Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs. in the context of an inter partes review).” slip op. at 10
Claim constructioncites Phillips · KSR · GrahamPatents in suitUS 9,722,104 - Lam Research Corp. v. Inpria Corp.All claims unpatentablePTAB · Apr 18, 2025 · IPR2024-00033 · APJ Grace Karaffa Obermann · IPR · Final written decision
Claims 1–12 are unpatentable as anticipated by the ’888 Publication; Patent Owner’s motion to add substitute claims 13–23 is granted.
RulingsFinal written decision- Novelty / Anticipation (§102) › Priority / effective filing date / continuation supportDecided for petitioner
“priority issue are based on the cited disclosures of the ’867 application discussed above. Ex. 2009 ¶ 29. For the reasons discussed above, we do not view the cited disclosures as sufficiently supporting Dr. Banerjee’s conclusion that the ’867 application provides support for claim 1’s average thickness range (id.) and, therefore, give this testimony little weight. Stated somewhat differently, Dr. Banerjee’s advances an opinion (really a legal one) that is not supported by the facts and not in line with the caselaw discussed in this section (such as RAI).” slip op. at 26
- Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityReference is prior artPrinted publication establishedDecided for petitioner
“priority issue are based on the cited disclosures of the ’867 application discussed above. Ex. 2009 ¶ 29. For the reasons discussed above, we do not view the cited disclosures as sufficiently supporting Dr. Banerjee’s conclusion that the ’867 application provides support for claim 1’s average thickness range (id.) and, therefore, give this testimony little weight. Stated somewhat differently, Dr. Banerjee’s advances an opinion (really a legal one) that is not supported by the facts and not in line with the caselaw discussed in this section (such as RAI).” slip op. at 26
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable
“d) Conclusion For the reasons discussed above, Petitioner has demonstrated by a” slip op. at 30
- PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend, grantedGranted
“For these reasons, Patent Owner has met its burden to show by a” slip op. at 34
Patent outcomesUS 9,823,564 unpatentable§ 102 anticipationcites Phillips · KSR · Graham · NautilusPatents in suitUS 9,823,564
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.