• Google LLC v. Sandpiper CDN, LLCAll claims unpatentable
  PTAB · Oct 9, 2026 · IPR2025-00826 · APJ Michael T Cygan · IPR · Final written decision

  Claims 1–23 are unpatentable under § 103, including over Glines alone and the additional asserted combinations.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art (“POSITA”) at the critical time “would have had at least a bachelor’s degree in computer science, electrical engineering, or a related field, and at least two years of work or research experience in the field of content delivery management or networks,” and that “additional education could substitute for work experience.” Pet. 3 (citing Ex. 1008 ¶¶ 51–53). Patent Owner provides substantially the same assessment. PO Resp. 16. We adopt Petitioner’s proposed level of ordinary skill, as it appears to be consistent with the specification of the ’112 patent and the prior art of record.” 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). Under this standard, the words of a claim generally are given their “ordinary and customary meaning,” which is the meaning the term would have to a person of ordinary skill at the time of the invention, in the context of the entire patent including the specification. Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc). Neither party proposes any express claim construction. Pet. 3; PO Resp. 16. We address the parties’ interpretation of the scope of “causing said hostname to be resolved” in our discussion of Petitioner’s assertions for limitation [1.d]. Based on the record before us, we determine that no claim term requires express construction.” slip op. at 8

  • Expert testimonyPetitioner expert creditedDecided for petitioner
  • Strike new argumentNew argument consideredDecided for petitioner

    “We do not agree. The Petition states that Glines discloses that the anycast is resolved by an ISP DNS server. Pet. 20. The Petition identifies Glines’s local ISP DNS resolver 18 as the claimed ISP DNS server. Id. The Petitioner further asserts that Glines’s ISP DNS resolver 18 sends the request to the DNS server 38, but states that “Glines’s local DNS resolver, an ISP DNS server, thus causes the hostname . . . to be resolved.” Id. at 21–22. The Petition also drew an analogy with the ’112 patent and the role of local DNS server 70a in the Petition. See Pet. 20–21. Because the Petition and the Reply both identify Glines’s local ISP DNS resolver 18 as causing the hostname to be resolved, Petitioner has not advanced a new theory of unpatentability in its Reply. 6 At oral argument, Patent Owner suggested a narrower claim reading, but admitted that this had not been briefed. Tr. 36:15–38:9, 44:9–16. We do not address this reading because it was not set forth in the briefing. In the briefing, Patent Owner took the broader reading discussed here. See Tr. 41:12–23; PO Sur-reply 7.” slip op. at 13

  Patent outcomesUS 9,021,112 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 9,021,112
• Micron Technology, Inc. v. Yangtze Memory Technologies Co., Ltd.No claims unpatentable
  PTAB · Jul 21, 2026 · IPR2025-00190 · APJ Kimberly Mcgraw · IPR · Final written decision

  Claims 1, 3–11, 13, and 14 were not shown unpatentable because Dong did not disclose the claimed vertical wordline arrangement, and the proposed 3D NAND combination lacked support for motivation and reasonable expectation of success.

  RulingsFinal written decision

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner

    “understanding that the claim term “from bottom to top” refers to the vertical arrangement of word lines in the memory portions from bottom to top and not from source end to drain end, as asserted by Petitioner. Inst. Dec. 17. In other words, the claim terms describing the first and second portions having word lines “from top to bottom” refer to the relative vertical location of the word lines within the memory portions and not to location of the word lines relative to the source or drain. Our construction is based on the plain and ordinary meaning of the express language of the independent claims, which states that the second memory portion is formed either above or below the first memory portion. The forming of one memory portion above or below another portion establishes a top and bottom in relation to those portions. For example, claim 5 is directed to a “program method of memory” that requires a second portion formed above the first portion. A second memory portion that is formed above a first memory portion is on top relative to the first portion. Similarly, claims 1 and 1 and 11, which recite a memory having a second portion formed below a first portion, establish that the second portion is on the bottom relative to the first portion. Thus, the claim language itself establishes the vertical locations of the memory portions relative to each other (e.g., a second memory portion that is above the first portion is on top, relative to the first portion). It follows that claim terms referring to the top and bottom of word lines within the memory portions also refer to relative vertical locations of the word lines within the memory portions. Thus, we understand the plain and ordinary meaning of claim” slip op. at 13

  • Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble limitingDecided for patent owner

    “In our Decision, we treated the preambles of claims 5 and 11 as limiting, noting that these preambles provide antecedent basis for the word line limitations recited in the body of their respective claim. Dec. 14–15, 8. Neither party disputes that the preambles of claims 5 and 11 are limiting. See PO Resp. 34–35 (agreeing that the preambles are limiting); see generally Reply 1–6 (not disputing that the preambles are limiting). We maintain our construction of the preambles in this Decision.” slip op. at 11

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “we consider the level of ordinary skill at the time of filing. 35 U.S.C. § 103; see also Graham, 383 U.S. at 17 (discussing pre-AIA obviousness). Petitioner contends that a person of ordinary skill in the art (“POSITA”) would have had a had a bachelor’s degree in electrical engineering or a similar discipline, along with 2–3 years of professional experience working with (e.g., researching, designing, or teaching) NAND memory devices (including issues relating to the operation, e.g., programming, of said devices), or an equivalent level of skill, knowledge, and experience (e.g., an advanced degree may replace some of the professional experience). Pet. 22 (citing Ex. 1004 ¶¶ 40–42). Petitioner also asserts that a POSITA would have been aware of and generally knowledgeable about NAND memory’s structure and fabrication, its component parts, how it operates, and how it is controlled. Id. at 22–23 (citing Ex. 1004 ¶ 41). In the Institution Decision, we adopted the assessment offered by Petitioner, which Patent Owner did not contest. Inst. Dec. 13. Following institution, Patent Owner stated it does not dispute Petitioner’s definition of a POSITA. PO Resp. 9 (citing Khatri Dec. ¶¶ 42–47). Because Petitioner’s definition of the level of skill in the art appears consistent with the ’941 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 9

  • Expert testimonyPatent owner expert creditedOther

    “We disagree and find that Dong’s Figure 5a does not depict wordlines in a physical vertical orientation, but rather depicts voltage diagrams. We agree with Patent Owner’s argument, supported by persuasive testimony by Dr. Khatri, that a POSITA would have understood that Dong’s voltage charts (e.g., Fig. 5a) simply represent which voltages are applied to which word lines and do not depict the physical orientation of the wordlines. See, e.g., Ex. 2028 ¶ 171 (citing Ex. 1005 ¶ 20; Ex. 1009 ¶¶ 52–54). As Dr. Khatri explains, Dong Figures 5a–5h depict different examples of self-boosting modes showing voltages applied differently to the wordlines and are not intended to depict the physical orientation of these word lines. Ex. 2028 ¶ 171; see also Sur-reply 11–12 (citing Ex. 1005 ¶¶ 47, 65, 63–67; Ex. 2028 ¶¶ 177–186). We agree with Dr. Kahtri’s persuasive testimony that a POSITA would understand that Figures 5a–5h are illustrated vertically, but do not represent the actual physical arrangement of the word lines in memory, which are shown to be horizontal in Dong’s Figure 4. See, e.g., Ex. 2028 ¶ 172 (citing Ex. 1005 ¶¶ 20, 45, 47, 87).” slip op. at 24

  Patent outcomesUS 11,568,941 not shown unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,568,941
• Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.All claims unpatentable
  PTAB · Jul 20, 2026 · IPR2025-00228 · APJ Michael T Cygan · IPR · Final written decision

  Claims 1–18 are unpatentable: claims 1, 2, 4, 5, and 9–18 as obvious over Kim; claims 1–18 over Kim and Fang; claims 1–15 over Han and Fang; and claims 17–18 over Han, Fang, and Chen.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art (“POSITA”) at the critical time “would have had a bachelor of science degree in electrical engineering or a similar discipline, along with 2-3 years of professional experience working with (e.g., researching, designing, or teaching) monolithic 3D structures and NAND flash memory devices, or an equivalent level of skill, knowledge, and experience (e.g., an advanced degree may replace some of the professional experience).” Pet. 26 (citing Ex. 1003 ¶42). Petitioner further asserts that a POSITA “would have been aware of and generally knowledgeable about 3D NAND’s structure, how it is manufactured, and its component parts.” Id. Patent Owner does not dispute this assessment. PO Resp. 7–8. For purposes of this Decision, we adopt Petitioner’s proposed level of ordinary skill, as it appears to be consistent with the specification of the ’276 patent and the prior art of record.” slip op. at 6

  • Expert testimonyPatent owner expert creditedDecided for patent owner

    “Dr. Campbell has a Ph.D. in physics, supplying the advanced degree that Petitioner’s definition of a person having ordinary skill in the art accepts as a replacement for some experience. Ex. 2006 ¶ 2. Dr. Campbell has significant experience in semiconductor technology, including in process technologies for submicron CMOS, years of research in semiconductor processing, materials, and device structures, and authored “[t]he leading textbook on semiconductor technology.” Id. ¶¶ 2–4. Dr. Campbell qualifies as a person of ordinary skill in the art under the parties’ agreed definition.” slip op. at 7

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

    “Patent Owner proposed that the terms “exposing portions” and “etching the exposed portions” require two different steps performed in that order. PO Resp. 7–10. Petitioner does not contest this characterization. Pet. Reply 1– 2. Patent Owner also proposes that this requires the exposure step not to perform any etching of the newly exposed layer. PO Resp. 10–12 (citing Ex. 1001, 10:2–5, 10:15–17 (stating that the etch-stop layer “protects the underlying structure until all the VIA openings 640 are formed” and that it “[t]he essence of an etch-stop layer dictates that contact-hole etching stops or slows down upon contact, i.e., exposing without penetrating it.” Pet. Reply 11. Based on the record before us, we determine that no claim term requires express construction for purposes of this Decision.” slip op. at 7

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

    “described in earlier embodiments would not be consistent with Kim’s statement that previously described elements are “omitted” in the Figures 17A to 22B section “for concise description.” As admitted by Patent Owner, it would be a “reasonable inference” that materials described in a first embodiment for a particular hypothetical layer L would also be used for that layer L in later embodiments absent an express statement to the contrary “because you have just omitted that sort of duplicative description.” Tr. 37:9–38:12. Kim’s Figures 17A–22B do not further address the underlying staircase structure that was detailed in the descriptions of the Figures 4–15 embodiments. Thus, it would similarly be a “reasonable inference” that aspects of the stack structure would be understood to apply to the same stack in the embodiments of Figures 17A–22B, which rely upon, in unaltered form, the earlier-described elements of the stack. stack on bottom, they “replace” and “exclude” any prior description of a gate-stack-on-top. PO Resp. 18–19 (citing Ex. 2019 ¶¶ 40–41; Ex. 1005 ¶¶ 185–187 (describing the etch-stop layer as covering the sacrificial layers only at their end portions)). However, as admitted by Patent Owner, all of Kim’s Figures show only a gate-stack-on-bottom structure. Tr. 41:6–7 (“For the first embodiment, it is true that figures show the gate stack on bottom.”). The fact that Kim’s Figures 17A–22B, which add etch-stop and barrier layers to the gate stack, are shown only as gate stack on bottom is merely consistent with the uniform use of gate-stack-on-bottom in Kim’s Figures, which show the layer-by-layer construction of its device. Like Figures 4–15, Figures 17A–22B exemplify rather than limit the description of the previously described memory stack, and do not exclude the gate-stack-onbottom description of the memory stack. Kim can be used for all it realistically teaches, including descriptions in its disclosure that are not represented by specific Figures. See In re Chapman, 357 F.2d 418, 424 (C.C.P.A. 1966) (stating that a reference “is not limited to the disclosures in its specific illustrative examples.”). Accordingly, the record supports Petitioner’s assertion that Kim’s teaching of a gate-stack-on-top alternative for the memory stack would be understood by a POSITA as a memory stack option applicable to its other embodiments having that same memory stack.” slip op. at 11

  Patent outcomesUS 11,101,276 unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 11,101,276
• Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.All claims unpatentable
  PTAB · Jun 9, 2026 · IPR2025-00189 · APJ Jo-Anne M Kokoski · IPR · Final written decision

  Claim 19 is unpatentable as obvious over Kim and over Nam; the challenge based on Lee and Park fails for lack of a reasonable expectation of success.

  RulingsFinal written decision

  • Adverse judgmentAdverse judgmentOther

    “B. Patent Owner’s Disclaimer of Claims 17 and 20 As indicated above, Patent Owner filed a statutory disclaimer of claims 17 and 20 of the ’666 patent. See Ex. 2005. In view of Patent Owner’s statutory disclaimer, we treat claims 17 and 20 as having never been part of the ’666 patent. See Vectra Fitness, Inc. v. TNWK Corp., ‘considered as part of the original patent’ in [35 U.S.C.] § 253 to mean that the patent is treated as though the disclaimed claims never existed.”). Because inter partes review cannot be instituted based on disclaimed claims, we do not consider claims 17 and 20 to be within the scope of this proceeding. 37 C.F.R. § 42.107(e) (“No inter partes review will be instituted based on disclaimed claims.”); General Elec. Co. v. United Techs. Corp., IPR2017-00491, Paper 9 (PTAB July 6, 2017) (precedential) (denying institution in view of a statutory disclaimer of all the challenged claims). Thus, we confine our analysis in this Decision to claim 19, the challenged claim that has not been disclaimed.” slip op. at 2

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “(“POSITA”) “would have had a bachelor’s degree in electrical engineering or a similar discipline, along with 2–3 years of professional experience working with (e.g., researching, designing, or teaching) 3D memory devices, or an equivalent level of skill, knowledge and experience (e.g., an advanced degree may substitute for professional experience).” Pet. 24–25 (citing Ex. 1003 ¶¶ 34–37). Petitioner further contends that the “POSITA would also have been aware of and generally knowledgeable about 3D memory’s structure, its component parts, and how it operates.” Id. at 25 (citing Ex. 1003 ¶¶ 34–37).” slip op. at 6

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner

    “evidence from the complete record now before us, we determine that the claim term “curved side surface” encompasses any outer surface of the structure with curvature. See Hamilton Beach Brands, Inc. v. F’real Foods, LLC, 908 F.3d 1328, 1338–1339 (Fed. Cir. 2018) (finding that it is acceptable for the Board to adopt its own claim construction where the parties “had notice of the contested claim construction and an opportunity to be heard”). We do not adopt Patent Owner’s position that “curved side surface” requires the side surface to be curved along a direction perpendicular to the top surface of the structure (e.g., the z-axis).” slip op. at 12

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

    “curved side surface” are premised on its proposed claim construction which, as set forth above, we decline to adopt. Instead, we determined that “curved side surface” as used in the challenged claim encompasses any outer surface of the structure with curvature, which does not need to be curved in any specific direction. See § II.B.1, supra. Kim states: Embodiments of the inventive concepts in which the protrusion pad PAD_P has a rectangular parallel[] shape is illustrated, but the protrusion pad PAD_P is not limited thereto and, in some embodiments, may have a shape including a curved surface based on a virtual rectangular parallel[] shape, a cylindrical shape, or any shape. Ex. 1005, 8:29–34 (emphases added). Dr. Lee testifies that “[a] POSITA would have recognized that this includes configurations where the sides of the protrusion pads are curved, particularly to optimize electrical connectivity and mitigate stress at material interfaces.” Ex. 1003 ¶ 201. Dr. Lee further testifies that a POSITA would have understood Kim’s disclosure “teaches a variety of different protrusion pad PAD_P shapes” including “pads with curved sides when viewed in cross-section or pads with curved sides when viewed from above.” Id. ¶ 202. Accordingly, we determine that Kim discloses a cylindrically-shaped PAD_P that has a “curved side surface” as required by the challenged claim. slip op. at 24

  Patent outcomesUS 11,145,666 unpatentable
  Claim construction§ 103 obviousnesscites Phillips
  Patents in suitUS 11,145,666
• Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.No claims unpatentable
  PTAB · Jun 9, 2026 · IPR2025-00118 · APJ Jo-Anne M Kokoski · IPR · Final written decision

  Claims 1–14 were not shown unpatentable because the Petition did not establish the claimed adjacent pad groups, common ESD bus, or pad-to-pad bonding wires.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedOther

    “would have had a bachelor of science degree in electrical engineering or similar discipline, and 2–3 years of professional experience working with (e.g., researching, analyzing, designing, or teaching) ICs, or equivalent level of skill, knowledge, and experience (e.g., an advanced degree may replace some of the professional experience and vice versa). This POSITA would have been aware of and generally knowledgeable about IC design, layout, manufacturing, packaging, and ESD protection. Pet. 18 (citing Ex. 1003 ¶¶ 29–33). Patent Owner states that it “does not dispute Petitioner’s proposed level of a” POSITA “for purposes of this IPR.” PO Resp. 10. In the Institution Decision, we adopted the assessment offered by Petitioner. Dec. 7. Because Petitioner’s definition of the level of skill in the art is consistent with the ’164 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 7

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

    “customary meaning of such claim as understood by one of ordinary skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. § 42.100(b). Under this standard, claim terms are generally given their plain and ordinary meaning as would have been understood by a person of ordinary skill in the art at the time of the invention and in the context of the entire patent disclosure. Phillips v. AWH Corp., 415 F.3d 1303, 1313 (Fed. Cir. 2005) (en banc). Only those terms in controversy need to be construed, and only to the extent necessary to resolve the controversy. Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019). Based on our review of the complete trial record and the arguments raised by the parties, we determine that it is not necessary to expressly construe any claim terms to resolve the parties’ dispute. Realtime Data, 912 F.3d at 1375.” slip op. at 7

  • Expert testimonyPatent owner expert creditedDecided for patent owner

    “includes segmented ground rails 350, 355. . . . The package substrate 310 includes a package common ground rail 360, and the segmented SoC ground rails 350, 355 are independently connected to the package common ground rail 360 via separate connections 370, 375 respectively.”). As set forth above, Dr. Foty describes the three ground lines in Saint Figure 7-7 as “segmented rails” when discussing the combination of Saint and Haralabidis, thus equating the three ground lines in Saint Figure 7-7 with Haralabidis’ segmented ground rail. Ex. 1003 ¶ 368. Neither Petitioner nor Dr. Foty, however, adequately addresses how or why a POSITA would have understood that the three separate grounds lines in Saint Figure 7-7 were “segmented rails” like the segments of the single ground line described in Haralabidis. In contrast, Dr. Khatri credibly testifies: Haralabidis teaches the use of a “common ground rail” to connect “segmented ground rails.” Haralabidis, 3:9–22, 3:34– 40, 3:65–4:12. A POSITA would understand “segmented ground rails” to refer to a single ground signal that has been “segmented.” That is fundamentally different from the design of Saint’s Figure 7-7 that Dr. Foty relies on, which uses three different ground signals, GND1, GND2, and GND3—not a single ground signal that has been “segmented.” Because of that, a POSITA would not have been motivated to change the Figure 7-7 design completely to connect three separate signals (GND1, GND2, and GND3) together as Dr. Foty proposes. Ex. 1003 ¶ 368. Indeed, for these reasons, a POSITA would have understood Haralabidis’ teachings of a “common ground rail” are inapplicable to Saint’s Figure 7-7. Ex. 2010 ¶ 129. Petitioner’s arguments and Dr. Foty’s testimony with respect to the modification of Saint Figure 7-7 leave an analytical gap that does not apprise us of why a POSITA would have modified Saint Figure 7-7 to include a common ESD bus as described in Haralabidis.” slip op. at 37

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentableNot shown unpatentable

    “For these reasons, we find that Yoshinaga’s statement that “[r]eference potential pads are not shown to simplify the drawing” indicates that reference potential pads are not depicted in Yoshinaga Figure 6, and determine that Yoshinaga Figure 6 does not disclose “a plurality of pad groups, adjacent and connected to the plurality of ESD buses” as recited in claim 6. Petitioner also argues that a POSITA would have understood that power supply pads 3, 4, and 58 in Yoshinaga “could just as readily be used as reference pads” and it would have been obvious “to use the pads immediately next to the saved areas as reference pads (e.g., pads 5 and 6) as pad assignments were left to the designer’s discretion.” Pet. 31 (citing Ex. 1003 ¶¶ 137–139). Petitioner asserts that “selecting which pads to use for ground, power signals, etc. is a design choice that depends on factors like chip size, the number of I/O signals, and the number of pads available.” Pet. 31 (citing Ex. 1003 ¶ 137–139). Petitioner states that such discretion would be to preserve Yoshinaga’s saved area for other circuitry as taught by Saint. Pet. 31–32 (citing Ex. 1003 ¶¶ 137–139; Pet. 19–23 (§ IX.A)). Neither Petitioner nor Dr. Foty adequately explain, however, why a POSITA would have made this specific design choice, namely, replacing power supply pads 3, 4, and 58 with reference pads. Pet. 31; Ex. 1003 ¶¶ 137–139; see also Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1069 n.4 (Fed. Cir. 2018) (“Merely stating that a particular placement of an element is a design choice does not make it obvious.” (quoting Cutsforth, Inc. v. MotivePower, Inc., 636 Fed. Appx. 575, 578 (Fed. Cir. 2016))). Petitioner offers the general proposition that pad assignments are left to the designer’s discretion, but this does not provide a reason why a POSITA would have been motivated to modify Yoshinaga Figure 6 as proposed. Pet. 31; Ex. 1003 ¶¶ 137–139. We have determined that Yoshinaga does not show (rather than does not label) reference pads. Because all of Yoshinaga’s illustrated pads are power supply pads, Petitioner’s proposed reassignment of pads would not be a simple matter of rearrangement of an existing mixture of power supply and reference pads, but require that reference pads be imported from elsewhere, and power supply pads be moved to some unspecified location. Petitioner’s arguments and Dr. Foty’s testimony with respect to the modification of Yoshinaga Figure 6 leave an analytical gap that does not apprise us of why a POSITA would have modified Yoshinaga Figure 6 to include reference pads in the place of power supply pads 3, 4, and 58. We agree with Patent Owner that none of Petitioner’s rationales” slip op. at 20

  Patent outcomesUS 10,879,164 not shown unpatentable
  Claim construction§ 103 obviousnesscites Phillips
  Patents in suitUS 10,879,164
• Micron Technology, Inc. v. Yangtze Memory Technologies Company, Ltd.No claims unpatentable
  PTAB · Jan 5, 2026 · IPR2024-00911 · APJ Kimberly Mcgraw · IPR · Final written decision

  Claim 10 was not shown unpatentable under § 103 over Toyama because the challenge did not remedy the deficiencies in its nonobvious base claim 8.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedOther

    “Petitioner’s proposed definition appears to be consistent with the cited prior art and the disclosure of the ’806 patent, and we adopt it for purposes definition of a POSITA.” slip op. at 8

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

    “In our Decision on Institution, we noted that the parties disputed construction of “each local contact” found in dependent claim 10, and “dielectric structure” recited in independent claim 8. Inst. Dec. 8–9. We determine that no express construction of “each local contact” recited in claim 10, or any other claim term, is required to resolve the issues in dispute in this proceeding.” slip op. at 9

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable

    “independent claim 8 would have been obvious for the reasons set forth in its petition in the 791-IPR. See id. at 1 (stating the present Petition maintains the same grounds set forth in IPR2024-00791). As explained in our Final Written Decision (Ex. 3001) in the 791-IPR issued concurrently, Petitioner did not show by a preponderance of the evidence that independent claim 8 would have been obvious over Toyama under any of Petitioner’s three alternative arguments. None of Petitioner’s arguments set forth in the present Petition, including the arguments directed to claim 10, remedy the deficiencies regarding its base claim 8. See Pet. 53–31, 98–101, 124–125; see also Reply. Accordingly, for the same reasons set forth in the Final Written Decision in the 791-IPR issued concurrently, Petitioner has not shown by a preponderance of the evidence that independent claim 8, and therefore dependent claim 10, would have been obvious over Toyama. See In re Fine, 837 F.2d 1071, 1076 (Fed. Cir. 1988) (“Dependent claims are nonobvious under section 103 if the independent claims from which they depend are nonobvious.”); Ex. 3001.” slip op. at 14

  • Expert testimonyNot reached

    “Petitioner relies on the Declaration of Jack C. Lee, Ph. D. (Ex. 1003) and the Reply Declaration of Jack C. Lee, Ph.D. (Ex. 1043) in support of its 2 The Leahy-Smith America Invents Act (“AIA”), Pub. L. No. 112–29, 125 Stat. 284 (2011), revised 35 U.S.C. §§ 102 and 103 effective March 16, 2013. Because the ’806 patent has an effective filing date after March 16, 2013 (Ex. 1001, codes (22), (63)), we refer to the AIA version of Sections 102 and 103. 3 Toyama, US Pub. No. 2017/0179026 A1, published June 22, 2017 (Ex. 1005). 4 Petitioner characterizes its alternative arguments of unpatentability of claim 10 as based on three “grounds.” See Pet. 15. Because each of Petitioner’s arguments are based on the same reference, albeit different embodiments, we characterize Petitioner’s challenges as three alternative arguments based on a single ground because each argument relies on the same reference. Ph.D. (Ex. 2005). Transcripts of the depositions of Dr. Lee (Exs. 2006, 2010) and of Dr. Yang (Ex. 1044) have also been submitted into the record.” slip op. at 7

  Patent outcomesUS 10,937,806 not shown unpatentable
  Claim construction§ 103 obviousnesscites Phillips
  Patents in suitUS 10,937,806
• Google LLC v. Sandpiper CDN, LLCInstituted
  PTAB · Nov 28, 2025 · IPR2025-00969 · APJ Michael T Cygan · IPR · Institution

  The Board instituted IPR on claims 1, 2, 22–24, and 26–46 over all asserted grounds, finding a reasonable likelihood that claim 1 is obvious over Kenner.

  RulingsInstitution decision

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

    “review. See 35 U.S.C. § 314 (2018); 37 C.F.R. § 42.4(a) (2023). The standard for instituting an inter partes review is set forth in 35 U.S.C. § 314(a), which provides that an inter partes review may not be instituted “unless . . . there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons given below, on this record, Petitioner has established a reasonable likelihood that it would prevail in showing the unpatentability of at least one of challenged claims 1, 2, 22–24, and 26–46 of the ’903 patent. Accordingly, we institute an inter partes review of the ’903 patent.” slip op. at 2

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “B. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art (“POSITA”) at the critical time “would have had at least a bachelor’s degree in computer science, electrical engineering, or a related field, and at least two years of work or research experience in the field of content delivery management or networks,” and that “[w]ork experience can substitute for formal education and additional formal education can substitute for work experience.” Pet. 5 (citing Ex. 1003 ¶ 47). Patent Owner does not provide any such assessment in its Preliminary Response. Prelim. Resp. 26. For purposes of this Decision, we adopt Petitioner’s proposed level of ordinary skill, as it appears to be consistent with the specification of the ’903 patent and the prior art of record.” slip op. at 6

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

    “Neither party proposes any express claim construction at this stage of the proceeding. Pet. 5; Prelim. Resp. 26. Based on the record before us, we determine that no claim term requires express construction for purposes of this Decision.” slip op. at 7

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

    “On the current record, we are persuaded by Petitioner that Kenner’s video ID is associated with a shared repeater server. As noted by Patent Owner, Kenner’s video ID includes content coordinate data that may “match with the regional IMs [repeater servers] that have subscribed to that type of file.” Prelim. Resp. 35 (citing Ex. 1005, 36:20–30). Kenner describes that content coordinate data is maintained on a database of each IM, which includes the Internet address of all other connected IMs and content coordinate data describing the type of files stored by the SRUs of each IM. Ex. 1005, 41:1–6. That content coordinate data, stored in each video ID and each IM, teaches the claimed association of alias with repeater server. Because the content coordinate data directs the PIM to the repeater server(s) having that particular data, Kenner’s user does not always access the same repeater server, and Patent Owner’s argument is unavailing.” slip op. at 12

  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,478,903
• Google LLC v. Sandpiper CDN, LLCInstituted
  PTAB · Nov 25, 2025 · IPR2025-00860 · APJ Sheila F Mcshane · IPR · Institution

  The Board instituted review of claims 1–20 on all asserted grounds, finding a reasonable likelihood that the Dilley, Pai, and Wang combination renders the claims obvious.

  RulingsInstitution decision

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

    “partes review. See 35 U.S.C. § 314; 37 C.F.R. § 42.4(a). Under 35 U.S.C. § 314(a), we may not authorize an inter partes review unless the information in the petition and the preliminary response “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons stated below, we determine that Petitioner has established a reasonable likelihood that it would prevail with respect to at least one claim. We therefore institute inter partes review as to all of the challenged claims of the ’573 patent and all of the asserted grounds of unpatentability in the Petition.” slip op. at 2

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “III. ANALYSIS A. Level of Ordinary Skill in the Art Petitioner asserts that a person of ordinary skill in the art: would have had at least a bachelor’s degree in computer science, electrical engineering, or a related field, and at least two years of work or research experience in the field of content delivery management or networks. Work experience can substitute for formal education and additional formal education can substitute for work experience. Pet. 12 (citing Ex. 1006 ¶ 70). Patent Owner asserts that “the Board does not need to resolve the appropriate level of skill for a POSA [person of ordinary skill in the art] for purposes of deciding institution because the Petition fails under any articulation of a POSA.” Prelim Resp. 10. For the purposes of this Decision, we adopt the assessment offered by Petitioner as it is consistent with the ’573 patent and the prior art before us. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).” slip op. at 8

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

    “Petitioner asserts that no claim terms need to be expressly construed by the Board and all terms should be given their ordinary meaning. Pet. 12. Patent Owner agrees that the Phillips standard applies. Prelim. Resp. 10. We determine that we need not expressly construe any claim terms at this juncture. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 9

  • Disclosure Requirements (§112) › Written description (Ariad)Written description adequateEntitled to earlier dateDecided for patent owner

    “We consider the disclosures of the Provisional Application, which refer to cases 1 and 2, in which requests are redirected to an origin server for lower popularity content and to a parent server for medium popularity content at steps 522 and 524 as shown in Figure 5, respectively, wherein the edge server receives a redirect from the popularity service without a “followme” flag. See Ex. 1011 ¶¶ 43, 44. The Provisional Application also discloses that, by comparison, if there is a “follow-me” redirect sent to the edge server, it obtains and caches a resource as shown at step 528 for higher popularity content. Id. ¶ 44. On this record, as Patent Owner asserts, these disclosures are consistent with technical reasons provided in the Provisional Application for instructing the edge server not to cache unpopular resources. See Ex. 1011 ¶¶ 68–69. In light of these disclosures, we preliminarily find support for Dr. Shenoy’s testimony that, even with the words “instruction to not cache” are not literally recited in the Provisional Application, caching and not caching are alternative options that indicate the instruction to the edge server that will be implemented for each option. See Ex. 2014 ¶ 56. Further, these disclosures provide support for Dr. Shenoy’s testimony that the disclosures “reasonably convey to those skilled in the art that Patent Owner had possession of the edge server receiving an instruction to not cache the resource (and instead simply forward the redirect).” Id. In re Johnson states that “it is not true that the factual context out of which the question under § 112 arises is immaterial. Quite the contrary. Here, . . . the ‘written description’ in the [] specification supported the claims in the absence of the limitation, and that specification, having described the whole, necessarily described the part remaining.” See Johnson, 558 F.2d at 1019. This is consistent with M.P.E.P. § 2173.05(i) which states, “[i]f alternative elements are positively recited in the specification, they may be explicitly excluded in the claims.” M.P.E.P. § 2173.05(i). Further, “the failure of the specification to specifically mention a limitation that later appears in the claims is not a fatal one when one skilled in the art would recognize upon reading the specification that the new language reflects what the specification shows has been invented.” All Dental Prodx, LLC v. Advantage Dental Prod., Inc., 309 F.3d 774, 779 (Fed. Cir. 2002). Even though we do not discern that the Provisional Application explicitly discloses an “instruction to not cache,” at least on this preliminary record, and for the purposes of this Decision, there is positive recital of instructions to cache in the Provisional Application and Petitioner has provided sufficient supporting evidence that caching and not caching are alternative options. Further, there is sufficient evidence, in the context of the disclosures of written description support in the Provisional Application, providing support for Dr. Shenoy’s testimony that Patent Owner had possession of an edge server receiving an instruction to not cache the resource. Nonetheless, we invite additional briefing on these issues, including issues relating to alternative options of caching and not caching. On this preliminary record, we find that the ’573 patent has a priority date of April 2, 2008, which predates the earliest possible date on which Newton-471 could be effective as prior art, September 30, 2014 (the date on which the earliest application in the priority chain of Newton-471 was filed). Accordingly, we preliminarily find that Newton-471 is not prior art to the challenged claims. Thus, on the present record, Petitioner has not demonstrated a reasonable likelihood that it would prevail in showing that claims 1–20 are anticipated by Newton-471.” slip op. at 13

  Claim construction§ 102 anticipation§ 103 obviousness§ 112 disclosurecites Phillips · KSR · Graham
  Patents in suitUS 10,924,573
• Merck Sharp & Dohme LLC v. The Johns Hopkins UniversityAll claims unpatentable
  PTAB · Nov 17, 2025 · IPR2024-00648 · APJ Devon Zastrow Newman · IPR · Final written decision

  Claims 1–30 are unpatentable: claims 1–2, 4–7, 9–12, 14–17, and 19–30 are anticipated by the MSI-H Study Record; claims 3, 8, 13, and 18 are obvious over the cited combinations.

  RulingsFinal written decision

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed patent owner constructionDecided for patent owner

    “We agree with Patent Owner that the phrase “in response to” in claim 1 requires a causal relationship wherein the patient must be tested for MSI-H and, if he or she is determined to be MSI-H or dMMR, then the patient is treated with 10 mg/kg of pembrolizumab every 14 days. In claim 1, a biological sample from the patient must be tested to determine if the cancer is MSI-H and, if so, the patient is treated with a therapeutically effective amount of pembrolizumab. For this reason, if the prior art teaches the limitations of 1) testing a biological sample obtained from a patient having cancer to determine that the patient’s cancer is microsatellite instability high or mismatch repair deficient, and 2) treating the patient with a therapeutically effective amount of pembrolizumab if the patient’s cancer is determined to be microsatellite instability high or DNA mismatch repair deficient, the art anticipates claim 1. We are not persuaded that claim 1 requires or excludes anything else because nothing else is recited in the claim.” slip op. at 10

  • Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityReference is prior artDecided for petitioner

    “Patent Owner does not direct us to evidence that it attempted to file any patent application before the publication date of the MSI-H clinical study and was denied an earlier filing date. Contrary to Patent Owner’s argument that it could not file a patent application without results from the MSI-H clinical study, we note that the inventors filed a provisional patent application on November 13, 2014, which, although also filed more than a year after the publication of the MSI-H clinical study, disclosed no clinical results or data. Ex. 1001, cover; Ex. 1030, 1. After considering the parties’ arguments, we are not persuaded by Patent Owner’s assertion that the inventors could not have filed an earlier application to at least attempt to secure a priority date before the MSI-H clinical study was publicly available. an earlier filing date. Instead, we are persuaded by Petitioner’s argument that because the MSI-H clinical study was published before the inventors filed an application to protect their patent rights the MSI-H clinical study is prior art for the information it discloses. Accordingly, we proceed to analyze Petitioner’s contentions in Ground 1.” slip op. at 24

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable

    “the genus disclosed in the MSI Study Record and does not argue or provide evidence to show that one of ordinary skill in the art could have envisaged each species within that genus. PO Resp. 11–14. We are not persuaded that either the size of the genus in the MSI Study Record or whether one of ordinary skill in the art would have been able to envisage every species within it is dispositive of whether the MSI Study Record anticipates claim 1, where one of ordinary skill in the art would have known that specific cancers recited in claim 1 would be included in the MSI Study Record. As Petitioner argues, claim 1 requires that “a patient…selected from the group consisting of [the listed cancers]” be tested and treated. Pet. Reply 10 (emphasis original). Claim 1 does not require that the patient have each and every one of the sixteen listed cancers to anticipate the claim. Rather, claim 1 requires testing a sample from “a patient” with one of the recited types of cancer and treating the patient. See Brown v. 3M, 265 F.3d 1349, 1351 (Fed. Cir. 2001) (“When a claim covers several structures or compositions, either generically or as alternatives, the claim is deemed anticipated if any of the structures or compositions within the scope of the claim is known in the prior art.”).” slip op. at 31

  • Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner

    “In contrast, the testimony of Patent Owner’s witness, Dr. Goldberg, supports Petitioner’s argument of the knowledge in the art at the time, wherein Dr. Goldberg testifies that “[w]hile many clinical oncologists were aware that patients with Lynch Syndrome had a defect in DNA mismatch repair, they associated MSI testing with young onset colorectal and endometrial cancer and patients with a family history of colorectal and/or endometrial cancer.” Ex. 2090 ¶ 79. Similarly, during his deposition, Dr. Goldberg also agreed that endometrial, gastric, and small-bowel cancers would come to mind when he saw a reference to MSI-high non-colorectal cancer. See Ex. 1243, 115:5–116:22 (Q. And so does endometrial cancer come to mind when you see reference to MSI-high non-colorectal cancers? . . . A. Yes. Q. As . . . a person of skill in the field, when you see reference to MSI-high non-colorectal cancers, does gastric cancer come to mind? . . . A. comes to mind. So the answer is yes. Q. As a person of skill in the field, when you see reference to MSI-high non-colorectal cancers, does small bowel cancer come to mind? . . . A. Yes.”). Patent Owner does not direct us to other evidence contradicting Petitioner’s argument that MSI-H was known to occur in endometrial, small bowel, and gastric cancer. Pet. 18.” slip op. at 30

  Patent outcomesUS 11,643,462 unpatentable
  Claim construction§ 102 anticipation§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 11,643,462
• Google LLC v. Sandpiper CDN, LLCInstituted
  PTAB · Nov 10, 2025 · IPR2025-00806 · APJ Sheila F Mcshane · IPR · Institution

  The Board instituted IPR on claims 1–20 and all asserted grounds, finding a reasonable likelihood of success on the § 103 challenges.

  RulingsInstitution decision

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

    “partes review. See 35 U.S.C. § 314; 37 C.F.R. § 42.4(a). Under 35 U.S.C. § 314(a), we may not authorize an inter partes review unless the information in the petition and the preliminary response “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons stated below, we determine that Petitioner has established a reasonable likelihood that it would prevail with respect to at least one claim. We therefore institute inter partes review as to all of the challenged claims of the ’517 patent and all of the asserted grounds of unpatentability in the Petition.” slip op. at 2

  • Disclosure Requirements (§112) › Written description (Ariad)Not entitled to earlier dateDecided for petitioner

    “application must comply with the written description requirement of 35 U.S.C. § 112.” Zenon Envtl., Inc. v. U.S. Filter Corp., 506 F.3d 1370, 1378 (Fed. Cir. 2007) (quoting Lockwood v. Am. Airlines, Inc., 107 F.3d 1565, 1571 (Fed. Cir. 1997)); see also In re Hogan, 559 F.2d 595, 609 (CCPA 1977). To comply with the “written description” requirement of 35 U.S.C. § 112, first paragraph, an applicant must “convey with reasonable clarity to those skilled in the art that, as of the filing date sought, he or she was in possession of the invention. The invention is, for purposes of the ‘written description’ inquiry, whatever is now claimed.” Vas-Cath, Inc. v. Mahurkar, 935 F.2d 1555, 1563–64 (Fed. Cir. 1991) (emphasis omitted). The invention claimed does not have to be described in ipsis verbis to satisfy the written description requirement. Union Oil Co. v. Atlantic Richfield Co., 208 F.3d 989, 1000 (Fed. Cir. 2000). The question of written description support should not be confused, however, with the question of what would have been obvious to the artisan. Whether one skilled in the art would find the claimed invention obvious in view of the disclosure is not an issue in the “written description” inquiry. In re Barker, 559 F.2d 588, 593 (CCPA 1977). “A description which renders obvious the invention for which an earlier filing date is sought is not sufficient.” Lockwood, 107 F.3d at 1572.” slip op. at 11

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

    “motivated to combine Beaumont and Hasan. Pet. 13–14. Petitioner argues that “Beaumont does not describe a specific interface for manually entering [policy and rules] preferences, Hasan discloses a GUI for exactly this type of policy specification.” Id. at 14 (citing Ex. 1003 ¶ 70). Petitioner asserts that Hasan discloses that its Java-based, “platform independent” GUI takes the form of a “familiar tree structure” and allows administrators to “configure device and service configuration data and policy information.” Id. (citing Ex. 1006, code (57), 7:7–26, 8:19–29, 18:9–20). Petitioner asserts that the combination of Beaumont and Hasan would have been straightforward, and a person of skill “would have been motivated to incorporate Hasan’s GUI so that administrators could conveniently configure preferences for Beaumont’s DNS servers through an intuitive interface.” Id. (citing, inter alia, Ex. 1003 ¶¶ 70–71; Ex. 1007 ¶ 23). Patent Owner does not present any arguments on the rationale to combine. See generally Prelim. Resp. We find that at this juncture Petitioner has presented sufficient rationale to combine Beaumont and Hasan.” slip op. at 16

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

    “We agree with Patent Owner that its understanding of a policy as a rule is consistent with the disclosure in the ’517 patent that “a policy may be created by generating a decision tree representing the ATC rules.” See Ex. 1001, 9:1–3. We do not agree with Patent Owner, however, that Beaumont in combination with Hasan does not disclose the claimed policy features as claimed. As discussed above, Petitioner relies upon Beaumont in combination with Hasan with its teachings on the use of Java-based GUIs in the form of a tree structure that allows administrators to configure device and service configuration data, as well as policy information. See Ex. 1006, code (57), 7:7–26, 8:19–29. For the policy teachings, Petitioner relies upon Beaumont’s “content provider DNS server that directs requests (traffic) according to a preference table (policy).” Pet. 15–16 (citing Fig. 1, ¶¶ 6, 17, 23). Petitioner also asserts that the Beaumont-Hasan GUI would enable an administrator to set policies for a selected content delivery server to allow setting server preferences and rules. Id. at 17–18 (citing, inter alia, Ex. 1007 ¶¶ 76–77). In support, Dr. Lin testifies that: The Beaumont-Hasan GUI would enable an administrator to select a content delivery server (e.g., in Japan) and set policies for that server. Hasan, 8:30–36, 10:25–34, 10:53–67; Beaumont, [0031]. For example, given the description in Hasan, selecting a server would bring up a menu enabling an administrator to assign the preferences shown in Fig. 3 of Beaumont. Hasan, 10:25–34; Beaumont, Figs. 2, 3, [0029]–[0031]. A POSITA would thus have recognized the combined GUI to “support[] the setting of said at least one policy using a decision tree representing rules” because it is presented in a “familiar tree structure” and would allow users to set server preferences and rules. Ex. 1003 ¶ 77 (emphasis added). Beaumont provides support for Dr. Lin’s testimony. Beaumont discloses that “rules such as selecting one [a server] based on user preferences can be used . . . [f]or example, a preference number can be assigned to each content delivery server and a destination domain.” Ex. 1007 ¶ 31. Beaumont further states that “FIG. 3 shows an illustrative example of incorporating preference numbers in a column.” Id. Thus, contrary to Patent Owner’s arguments, Beaumont discloses that rules or policies, represented by the preference number, are represented in the table shown in Figure 3 of Beaumont. Dr. Lin also testifies that in the Beaumont-Hasan combination “the GUI supports the setting of” policy is taught. Ex. 1003 ¶ 77. Hasan provides support that service policies can be modified by the use of a GUI. See Ex. 1006, 8:30–36, 10:25–34, 10:53–67. Accordingly, in the combination of Beaumont and Hasan, wherein the preference database is replaced by the GUI decision tree, Petitioner has provided sufficient evidence at this juncture that the combination of Beaumont and Hasan teaches that the GUI obtains a policy, the preference number, for the direction of network traffic, where the GUI supports the setting of the policy using a decision tree representing rules.” slip op. at 19

  Claim construction§ 103 obviousness§ 112 disclosurecites Phillips · KSR · Graham
  Patents in suitUS 8,645,517

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.