• Uatp IP LLC v. Slick Slide LLCSome claims unpatentable
  PTAB · Oct 2, 2026 · PGR2024-00054 · APJ Brian D Range · PGR · Final written decision

  Claims 22–26 are unpatentable based on obviousness; claims 1–17, 27, and 28 were not shown unpatentable. Patent Owner’s motion to terminate was denied.

  RulingsFinal written decision

  • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for patent owner

    “1. Mesh Layer Petitioner contends “no formal claim construction is necessary in this” slip op. at 13

  • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable

    “5. Analysis On this complete record, we determine that Petitioner’s arguments do” slip op. at 31

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

    “form of nylon and some form of Teflon (and possible combinations thereof) having the specific coefficient of friction range given in limitation [1c] breaks down, because the building blocks of the obviousness argument are not sufficiently identified in Phillips alone, nor in the supporting testimony. Accordingly, we determine that Petitioner’s arguments and evidence fail to show that Phillips renders the challenged claims obvious. 6. Conclusion Based on the foregoing, we determine that Petitioner has not established by a preponderance of the evidence that claims 1–4, 6, and 7 would have been anticipated by or obvious in view of Phillips.” slip op. at 33

  • Obviousness (§103) › Objective indicia / secondary considerations › NexusObjective indicia no nexusDecided for petitioner

    “2. Products and Nexus We first consider the issue of whether certain evidence relied upon by” slip op. at 20

  Patent outcomesUS 11,998,854 mixed
  Claim construction§ 102 anticipation§ 103 obviousness§ 112 disclosurecites Phillips · Graham · Nautilus
  Patents in suitUS 11,998,854
• Apple Inc. v. Smith Interface Technologies, LLCSome claims unpatentable
  PTAB · Jan 14, 2026 · IPR2024-01089 · APJ Sharon Fenick · IPR · Final written decision

  Claims 1, 2, 9–11, 13, 15, 16, 56–64, and 84 are unpatentable as obvious; claim 14 was not shown unpatentable because the motivation to combine the gesture teachings was not established.

  RulingsFinal written decision

  • Skill levelSkill level board ownDecided for petitioner

    “In our Decision on Institution, we noted that Petitioner’s definition left it unclear whether the bachelor’s degree in the proposed definition would be considered by Petitioner to be “an advanced-level degree,” and did not adopt the portion of the definition relating to the substitution of years of experience for a degree. Dec. on Inst. 9. Additionally we did not adopt Petitioner’s proposed additional requirement that one of ordinary skill of the pertinent technologies employed by the ’212 patent.” Id. We adopted, for the purposes of the Decision on Institution, the portion of the definition proposed by Petitioner requiring “a bachelor’s degree in computer science, computer engineering, or a comparable field and at least two years of professional experience working with graphical user interfaces and applications for computers” as “consistent with the problems and solutions in the ’212 patent and prior art of record and . . . supported by declarant testimony.” Id. Patent Owner adopted this definition (PO Resp. 12–13), noting Dr. Cockburn’s testimony regarding this definition (Ex. 2006, 12:15– 21). Patent Owner’s declarant, Dr. Madisetti, also agreed with and adopted this definition. Ex. 2005 ¶¶ 23–25. For the same reasons discussed in the Decision on Institution, we again adopt this definition.” slip op. at 8

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

    “C. Claim Construction The parties’ papers include some discussion of claim construction. PO Resp. 13–17; Pet. Reply 1–2; PO Sur-reply 2–3. Each party asserts, and we agree, that there is no controversy that would require us to decide any claim construction issue. Pet. Reply 2; PO Sur-reply 3; see Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 9

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
  • Expert testimonyPetitioner expert creditedPatent owner expert discountedDecided for petitioner

  Patent outcomesUS 10,671,212 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,671,212
• Apple Inc. v. Smith Interface Technologies, LLCSome claims unpatentable
  PTAB · Jan 14, 2026 · IPR2024-01088 · APJ Sharon Fenick · IPR · Final written decision

  Claims 1, 9, 12, 19–22, 24–32, 36–43, 47, 58, 59, 63, 71, 74, 81–84, 86–94, 97–105, 109, 119–121, and 124 are unpatentable over Chaudhri, Martyn, and Griffin; claims 35 and 57 are not.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “In our Decision on Institution, we noted that Petitioner’s definition left it unclear whether the bachelor’s degree in the proposed definition would be considered by Petitioner to be “an advanced-level degree,” and did not adopt the portion of the definition relating to the substitution of years of experience for a degree. Dec. on Inst. 9. Additionally we did not adopt Petitioner’s proposed additional requirement that one of ordinary skill “would have possessed extensive background knowledge and understanding of the pertinent technologies employed by the ’758 patent.” Id. We adopted, for the purposes of the Decision on Institution, the portion of the definition proposed by Petitioner requiring “a bachelor’s degree in computer science, computer engineering, or a comparable field and at least two years of professional experience working with graphical user interfaces and applications for computers” as consistent with the problems and solutions in the ’758 patent and prior art of record and supported by declarant testimony. Cockburn’s testimony regarding it (Ex. 2007, 9:7–23), and, for the same reasons discussed in the Decision on Institution, we adopt it here.” slip op. at 9

  • Expert testimonyPetitioner expert creditedDecided for petitioner

    “We determine that Petitioner has sufficiently shown that one of ordinary skill in the art would have combined the snapshot menu and pressand-hold gesture of Martyn with Chaudhri as Petitioner proposes, resulting in a device that provides a contextual shortcut sub-menu of common application functions in response to a touch-and-hold user input. We credit Dr. Cockburn’s testimony in Petitioner’s showing that Martyn’s contextual allow the user to accomplish recurring tasks more quickly. Pet. 15–17 (citing, inter alia, Ex. 1003 ¶¶ 61–62, 66–67). Contrary to Patent Owner’s contentions, Petitioner provides a showing of a motivation to use, in the resulting combination, both Martyn’s menu and its mechanism for calling the menu. Pet. 15–17 (citing Ex. 1003 ¶¶ 49–53, 63); Ex. 1067 ¶ 21. We credit Dr. Cockburn’s supported testimony of the motivation for the combination Petitioner proposes, using the teachings of Martyn identifying its App Snapshot called through a press-and-hold as allowing a user access to multiple options pertaining to one application at one time in one menu, for ease and speed of navigation. Pet. 15–18; Ex. 1003 ¶¶ 61, 63 & n.3, 68 (citing Ex. 1005 ¶¶ 4–8, 15); Ex. 1067 ¶¶ 20, 21. Additionally, we credit Dr. Cockburn’s testimony regarding the analogousness of the touch-and-hold mechanism to trigger the menu to the press-and-hold trigger for the menu in Martyn, which Patent Owner criticizes as unsubstantiated (PO Sur-reply 18) but we find to be supported by record evidence. Pet. 16 (citing Ex. 1003 ¶¶ 49–53, 63); Reply Br. 17 (citing Ex. 1067 ¶¶ 16–22), 20 (citing Ex. 1067 ¶¶ 30) ; Ex. 1003 ¶¶ 53 (citing, inter alia, Ex. 1022 ¶ 183), 63 & n.3.” slip op. at 18

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

    “at first contending that these limitations require a continuous touch meeting both limitations; however, Patent Owner withdrew the request to construe the claim to require one continuous gesture to meet the two limitations, agreeing with Petitioner’s assertion that either one continuous gesture or two separate gestures could meet the limitations. PO Resp. 15–18; Pet. Reply 3– 5; PO Sur-reply 3–4; Tr. 28:20–29:2. Because we agree with the parties that this is the correct construction, there is no remaining controversy regarding this construction that would require us to decide any claim construction issue. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 10

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner

    “We determine that Petitioner has sufficiently shown that one of ordinary skill in the art would have combined the snapshot menu and pressand-hold gesture of Martyn with Chaudhri as Petitioner proposes, resulting in a device that provides a contextual shortcut sub-menu of common application functions in response to a touch-and-hold user input. We credit Dr. Cockburn’s testimony in Petitioner’s showing that Martyn’s contextual allow the user to accomplish recurring tasks more quickly. Pet. 15–17 (citing, inter alia, Ex. 1003 ¶¶ 61–62, 66–67). Contrary to Patent Owner’s contentions, Petitioner provides a showing of a motivation to use, in the resulting combination, both Martyn’s menu and its mechanism for calling the menu. Pet. 15–17 (citing Ex. 1003 ¶¶ 49–53, 63); Ex. 1067 ¶ 21. We credit Dr. Cockburn’s supported testimony of the motivation for the combination Petitioner proposes, using the teachings of Martyn identifying its App Snapshot called through a press-and-hold as allowing a user access to multiple options pertaining to one application at one time in one menu, for ease and speed of navigation. Pet. 15–18; Ex. 1003 ¶¶ 61, 63 & n.3, 68 (citing Ex. 1005 ¶¶ 4–8, 15); Ex. 1067 ¶¶ 20, 21. Additionally, we credit Dr. Cockburn’s testimony regarding the analogousness of the touch-and-hold mechanism to trigger the menu to the press-and-hold trigger for the menu in Martyn, which Patent Owner criticizes as unsubstantiated (PO Sur-reply 18) but we find to be supported by record evidence. Pet. 16 (citing Ex. 1003 ¶¶ 49–53, 63); Reply Br. 17 (citing Ex. 1067 ¶¶ 16–22), 20 (citing Ex. 1067 ¶¶ 30) ; Ex. 1003 ¶¶ 53 (citing, inter alia, Ex. 1022 ¶ 183), 63 & n.3.” slip op. at 18

  Patent outcomesUS 10,656,758 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 10,656,758
• Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Empire Technology Development LLCSome claims unpatentable
  PTAB · Dec 9, 2025 · IPR2024-00896 · APJ Andreas Baltatzis · IPR · Final written decision

  Claims 25–28 are unpatentable as obvious over the asserted Li-based combinations; claim 29 was not shown unpatentable over Li, Siam, and Tiirola.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “relevant to the challenged claims, as of the earliest claimed priority date, “would have had a bachelor’s degree in electrical engineering, computer science, computer engineering, or a related field, and two-to-three years of experience in the research, design, development, or testing of wireless data communication systems at the physical and media access control (MAC) layer.” Pet. 8 (citing Ex. 1002 ¶¶ 30–34). Patent Owner does not oppose Petitioner’s definition of a person of ordinary skill in the art. See PO Resp.; see also Ex. 2022 ¶ 22 (adopting “Petitioners’ and Dr. Valenti’s proposed definition of a person of ordinary skill in the art.”) On the complete record, we determine Petitioner’s proposed level of skill comports with the qualifications a person would have needed to understand and implement the teachings of the ’120 patent and the prior art of record. C. Claim Construction” slip op. at 10

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

    “court in the parallel litigation issued a final claim construction. Pet. Reply 2; PO Sur-Reply 3–5. The district court construed “idle power consumption” as “a power consumed by the mobile station when the mobile station is powered on and waiting to send.” Ex. 1050, 12. The parties propose that we construe the claims to match the district court’s final construction. See Pet. Reply 2; PO Sur-Reply 3; Tr. 26. We agree and adopt the district court’s final claim construction of “idle power consumption” as “a power consumed by the mobile station when the mobile station is powered on and waiting to send,” for the reasons set forth below.” slip op. at 11

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

    “2. Additional Claim Terms For purposes of institution, we determine that no other claim terms require express construction. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.”)). D. Asserted Obviousness of Claims 25, 27, and 28 over Li and Siam” slip op. at 15

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

    “On the full record, we find that a preponderance of the evidence supports Petitioner’s argument that one skilled in the art would have been motivated to combine Li and Siam to reduce total power consumption including idle power consumption (Li) and circuit power consumption (Siam). Both Li and Siam describe a need for reducing energy consumption in wireless devices. See Ex. 1005 ¶ 18; Ex. 1006, 875–76. Both references further describe switching from MIMO mode to another operating mode to reduce power consumption and optimize battery life. See Ex. 1005 ¶ 19; Ex. 1006, 875 (“[W]e dynamically adjust the ‘transmission mode’ . . . so as to minimize the total energy consumption.”). In sum, the references teach the same technique, i.e., mode switching, to achieve the same goal, i.e., reducing energy consumption, in similar devices, i.e., wireless devices. See KSR, 550 U.S. at 417 (“[I]f a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would unless its actual application is beyond his or her skill.”). Accordingly, we are persuaded by Petitioner’s argument and evidence that one skilled in the art would have combined the Li and Siam with a reasonable expectation of success in doing so. See Ex. 1002 ¶¶ 91, 92.” slip op. at 20

  Patent outcomesUS 8,798,120 mixed
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,798,120
• Arashi Vision (U.S.) LLC (D/B/A Insta360) v. Gopro, Inc.Some claims unpatentable
  PTAB · Dec 2, 2025 · IPR2024-01052 · APJ Brian D Range · IPR · Final written decision

  Claims 1, 2, 7–12, and 17–20 are unpatentable as obvious; claims 3–6 and 13–16 were not shown unpatentable because the asserted Watanabe combinations were unsupported.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “cameras.” Pet. 6 (citing Ex. 1002 ¶¶ 36–38). Petitioner further contends “[a]n advanced graduate degree in the disciplines cited above may make up for the work experience indicated above.” Id. Patent Owner does not dispute and applies Petitioner’s proposed level of skill. PO Resp. 6. We find that Petitioner’s proposal is reasonable and consistent with the ’832 patent specification and the prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art). Thus, we apply Petitioner’s proposal in our analysis.” slip op. at 13

  • Prior constructionPrior construction adoptedDecided for petitioner

    “In our Institution Decision, we construed “determin[ing] a viewing window for the visual content as a function of progress through the progress length” as “requiring determining a viewing window for different times of the video.” Inst. Dec. 21. Neither party disputes this construction. PO Resp. 7; Pet. Reply 1–7. We maintain this same construction.” slip op. at 13

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

    “Thomason are in the same field of endeavor. Thomason describes a camera and method for correctly orientating pictures from the camera. See, e.g., Ex. 1004 ¶¶ 1, 2 29–40, Figs. 3a–3b. In particular, Thomason is interested in rotating and cropping images to reduce the effect of poor orientation. Pet. 9 (citing Ex. 1004 ¶¶ 2, 34, 36). Pacurariu likewise describes aligning and resizing/cropping of a captured image to correct poor orientation. See, e.g., Ex. 1005 ¶¶ 1, 3, 45–56, Figs. 5A–5C. The preponderance of the evidence also supports that a person having ordinary skill in the art would have had reason to combine the Pacurariu’s teachings with Thomason to predictably improve Thomason. Thomason teaches correct rotation of video data and makes use of rotation sensor to correct rotated images. Pet. 19–21 (citing, e.g., Ex. 1004 ¶¶ 4, 27, 29, 35; Ex. 1002 ¶¶ 76–77). Pacurariu similarly uses sensors and measures tilt angle of the camera. Id at 21–22 (citing, e.g., Ex. 1005 ¶¶ 51–52, Fig. 6; Ex. 1002 ¶ 78). Pacurariu further teaches that its tilt data angle can be stored for each “video frame.” Id. at 22 (citing Ex. 1005 ¶ 52). Petitioner, with support from credible testimony of Dr. Katsaggelos, explains how the teachings of Thomason and Pacurariu could be successfully combined. Id. at 23 (citing, for example, Ex. 1002 ¶ 81). A person of ordinary skill in the art could have known that Thomason’s system could be improved by saving rotation data for each video frame and correcting images on a frame-by-frame basis. Id. at 23–24. The testimony of Dr. Katsaggelos is credible in this regard. Ex. 1002 ¶¶ 80–81. Petitioner and Dr. Katsaggelos explain the references’ teachings and, based on these teachings, assert that a person having skill in the art would have had reason to combine with reasonable expectation of success based on those teachings. Reason to combine may properly come from the references themselves. KSR Int’l Co., 550 U.S. at 418 (explaining reason to combine may come from “interrelated teachings of multiple patents”). Based on the evidence presented, Petitioner establishes by a preponderance of the evidence that a person having ordinary skill in the art would have had reason to combine the teachings of Thomason and Pacurariu with a reasonable expectation of success. Ex. 1002 ¶¶ 76–81, 89–92; Ex. 1004 ¶¶ 4, 8–9, 27, 29, 35; Ex. 1005 ¶¶ 26, 41, 46, 51–52, 55–57, Figs. 6, 7.” slip op. at 27

  • Obviousness (§103) › Objective indicia / secondary considerations › NexusObjective indicia no nexusDecided for patent owner

    “evaluating nexus between the claimed invention and objective evidence of nonobviousness, also referred to as secondary considerations. Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 33 at 33 (PTAB Jan. 24, 2020) (precedential). We first consider whether Patent Owner has demonstrated “that its products are coextensive (or nearly coextensive) with the challenged claims,” resulting in a rebuttable presumption of nexus. Id. at 33. If not, that “does not end the inquiry into secondary considerations”; “the patent owner is still afforded an opportunity to prove nexus by showing that the evidence of secondary considerations is the ‘direct result of the unique characteristics of the claimed invention.’” Id. (quoting Fox Factory, 944 F.3d at 1373–75).” slip op. at 62

  Patent outcomesUS 11,336,832 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 11,336,832
• Arashi Vision (U.S.) LLC (D/B/A Insta360) v. Gopro, Inc.Some claims unpatentable
  PTAB · Nov 26, 2025 · IPR2024-00984 · APJ Nabeel U Khan · IPR · Final written decision

  Claims 6 and 7 are unpatentable as obvious over Meulen and Chao; claim 1 was not shown unpatentable because Meulen does not disclose transforming an image captured by its camera.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner argues that a person of ordinary skill in the art in the relevant field “would have a bachelor’s degree in engineering or computer science, or equivalent field, and two years of experience working on image or video processing, or digital cameras,” or alternatively “would have four years of experience working on image or video processing, or digital cameras.” Pet. 6. Petitioner further argues that an “advanced graduate degree” may “make up for the work experience.” Id. (citing Ex. 1002 ¶¶ 33–34). “Patent Owner applies Petitioner’s proposed level of skill.” PO Resp. 4–5 (citing Ex. 2027 ¶¶ 19–20). We adopt Petitioner’s proposed level of ordinary skill because it is consistent with the level of skill in the art at the time of the invention as reflected by the ’413 patent and the cited prior art.” slip op. at 9

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

    “From the outset we note that the words of the claim recite “non- uniformly shift[ing] the pixels” and do not recite a “non-linear” transformation. This favors Petitioner’s position, which is based directly off the definition of “non-uniform,” over Patent Owner’s position, which substitutes “non-linear” for “non-uniform.” Generally, then, we would determine the ordinary and customary meaning of the claim term in the context of the entire Specification. Here, however, the ʼ413 patent does not mention “uniform” or “non-uniform” shifting of pixels anywhere except in the claims. The Specification, therefore, provides limited guidance, by itself, as to the ordinary and customary meaning of the term. Nonetheless, even reviewing the portions of the Specification cited by the parties, we see no clear or unambiguous effort to limit the challenged claims to require only non-linear transformations in which the pixels to which a transformation is applied do not have the same amount of shift. is not non-linear. Pet. Reply 1. Specifically, Petitioner argues that the center circle of Figure 2B maintains the original circular shape after the transformation is applied to the image which contradicts Patent Owner’s argument that no two pixels will have the same amount of shift. Pet. Reply 1–2. We agree. In Figure 2B of the ʼ413 patent, the center of the image is chosen to be the region of interest. Ex. 1001, 4:19–21. After the input image goes through linear scaling (step 204) and then non-linear warping (step 206) the circles become more vertically compressed as they approach the top and bottom edges and more horizontally stretched as they approach the left and right edges. Id. at 4:22–30. But “the center circle is fully corrected so that it maintains the original circular shape of the corresponding circle in the input image 212.” Id. at 4:23–25. This means that at least some pixels, such as those of the center circle, undergo the same amount of shift after being transformed.” slip op. at 11

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

    “readable instructions” of claims 1 and 2 must occur in a particular order. Specifically, Patent Owner argues that the step of “determine a portion within the input image” must occur after “obtain[ing] an image” and before “apply[ing] a transformation to the input image.” PO Resp. 17 (citing Ex. 2027 ¶ 59). Petitioner argues, on the other hand, that the specification does not require such an order and, in fact, describes an embodiment where such an order is not followed. Pet. 3. We determine that the “determine a portion within the input image” step does not need to occur after the “obtain an image” step and before the “apply a transformation to the input image” step. As Patent Owner itself points out, claims 1 and 2 are apparatus and system claims respectively, and an ordering of the limitations of such claims is not necessary. PO Resp. 17. Even if we were to treat the apparatus and system claims as reciting the steps of a method, “as a general rule the claim is not limited to performance of the steps in the order recited, unless the claim explicitly or implicitly requires a specific order.” Baldwin Graphic Systems, Inc. v. Siebert, Inc., 512 F.3d 1338, 1345 (Fed. Cir. 2008) (citing Interactive Gift Express, Inc. v. Compuserve Inc., 256 F.3d 1323, 1342–43 (Fed. Cir. 2001)). We see nothing in the claims that would cause us to break this general rule. Patent Owner argues that the claims imply a “specific order because the ‘determine a portion’ requirement operates on ‘the [obtained] input image’ and defines the ‘portion’ that is necessary for the 23; Ex. 2027 ¶ 59). Although the steps are recited in a specific order in the claim, as they necessarily must be, the claim does not expressly specify that the certain steps must occur before or after other instructions, nor does logic imply such a requirement. For example, if certain characteristics of the image are known before the image is obtained (e.g. the size, dimensions, resolution, aspect ratio, or content etc.) the determination of the portion of the image could be made before the image is obtained. These characteristics may be based on the specific device taking the image or the subject matter of the image, both of which may be known before the image is captured or obtained. It is, therefore, not necessary that the image be obtained in order for a portion of the image to be determined. Similarly, we do not find the written description to expressly or implicitly specify an order the claimed step of “determine a portion of the input image.” For example, the written description of the ʼ413 patent states that in Figure 2B “the center of the image is chosen to be the region of interest that is most fully corrected and the distortion increases in each direction as the frame boundary is approached.” Ex. 1001, 4:19–22. Patent Owner emphasizes that this disclosure implies that an input image is obtained before the center portion is chosen. PO Resp. 19 (citing Ex. 1001, 3:63–64, 4:19–22). But the description of this embodiment does not expressly recite an order. For example, the description of Figure 2A explains that “an input image is obtained” in step 202, “the image is then scaled” in step 204, and a “non-linear warping is then applied” in step 206. Ex. 1001, 3:63–4:3. This description does not mention “determin[ing] of a portion of the image” as a separate step or as part of the listed steps, and therefore, does not specify an order in which this step must occur. is configured so that some areas of the image are fully corrected geometrically, while some other areas are distorted. . . . [T]he center of the image is chosen to be the region of interest that is most fully corrected and the distortion increases in each direction.” Id. at 4:17–19. This excerpt from the ʼ413 patent, which the Patent Owner specifically relies on (PO Resp. 19), also does not specify an order in which the determination step (choosing of the region of interest) takes place. Moreover, because the ʼ413 patent states that the warp module is configured so that some areas are fully corrected while others are not, the determination step could take place at the time the warp module was configured, presumably before the image was obtained. Finally, the ʼ413 patent states that “in the case, of video, the area may dynamically change between images (e.g. to follow a moving object).” Ex. 1001, 4:34–36. Patent Owner argues that this description “requires first obtaining the image in order to locate the object that is being followed.” PO Resp. 19–20. This embodiment is related to the case of video or a moving object, which the challenged claims do not mention. We, therefore, decline to limit the scope of the claim based on this embodiment. Phillips v. AWH Corp., 415 F.3d 1303, 1323 (Fed. Cir. 2005) (en banc) (“[A]lthough the specification often describes very specific embodiments of the invention, we have repeatedly warned against confining the claims to those embodiments.”).” slip op. at 14

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner

    “Having reviewed the parties’ arguments and cited evidence we determine Petitioner has established, by a preponderance of the evidence, that a POSITA would have been motivated to combine Meulen and Chao. For example, Petitioner argues that “[i]t would have been obvious that when performing image scaling, pixels from the input to output positions are shifted based on a scaling factor.” Pet. 91. Meulen teaches scaling but does not provide the details regarding scaling. E.g., Ex. 1007, 1:55–56, 4:37–49. We agree that in light of Meulen’s disclosure of scaling, a POSITA would have looked to other references, such as Chao, for further details on how to perform scaling. Dr. Katsaggelos provides credible support, testifying that “Meulen mentions ‘compression and/or scaling,’ and provides details on how to perform compression. But Meulen does not disclose the details of how to perform scaling. A POSITA when faced with Meulen and having the knowledge about scaling would have been motivated to turn to a prior art reference that discloses the details of scaling.” Ex. 1002 ¶ 262. Patent Owner argues that Petitioner provides no motivation to combine other than asserting that it involves combining prior art elements. PO Resp. 35 (quoting Pet. 92). As explained above, however, Petitioner does more than just assert that the motivation involves combining prior art elements. Instead, Petitioner explains that Meulen discusses both compression and scaling, and provides details regarding compression but does not provide details on how to scale. Pet. 91–92; Ex. 1002 ¶¶ 262–262. Thus, Meulen teaches that scaling was a known technique. See Hybritech, (“a patent need not teach, and preferably omits, what is well known in the art”). Dr. Katsaggelos testifies that, in this situation, a POSITA would have looked to Chao for details regarding scaling. Ex. 1002 ¶¶ 262–263. We determine this establishes, by a preponderance of the evidence, that a POSITA would have had reason to combine Meulen’s teachings with Chao. Patent Owner draws a distinction between Meulen and Chao, arguing that “Meulen is concerned with modifying content from a media source to be displayed on a device’s screen while Chao, by contrast, is directed to changing the aspect ratio of a document intended for printing.” Id. at 36 (citing Ex. 2027 ¶¶ 89–90). Patent Owner’s argument is contradicted, however, by Chao’s disclosure which states that “after all the background and foreground elements in the image have been resized . . . [t]he image may be output by displaying the image on or as part of: a display screen such as a computer monitor, camera screen, printer screen, printed page, projected image, or the like.” Ex. 1008 ¶ 32. Patent Owner argues that Meulen’s system avoids distortion near the middle where the user’s focus is more likely to be, while Chao, on the other hand, is directed to avoiding distortion of stylized borders on differently sized pages. PO Resp. 36–37 (citing Ex. 1006, 1:26–29; Ex. 1008 ¶¶ 1, 25; Ex. 2027 ¶¶ 91–92). This argument reads the prior art too narrowly and does not address Petitioner’s combination. Petitioner does not rely on Chao for its teaching of avoiding distortion near the borders of the image, but rather on its teaching of scaling the image while maintaining the design intent of the original image. Ex. 1008 ¶ 22; Ex. 1014 ¶ 67. Thus, Petitioner is applying Chao’s techniques of scaling (regardless of where the area of 92. Finally, Patent Owner argues that Chao’s approach of stretching/shrinking only the background and uniformly scaling entire foreground objects is suitable for graphic design but incompatible with Meulen which is concerned with adapting externally derived media source content for display on a fixed size screen. PO Resp. 37–38 (citing Ex. 2027 ¶ 93). We disagree with Patent Owner’s argument because it does not address Petitioner’s combination. Petitioner relies on Chao’s teaching of stretching/shrinking of background elements and applies that stretching/shrinking to Meulen’s images displayed on its screen. Pet. 91–92 (citing Ex. 1008 ¶¶ 28, 63; Ex. 1002 ¶ 263). The fact that Chao applies its teaching to graphic design does not prevent a POSITA from applying those teachings to Meulen’s media content displayed on its screen.” slip op. at 20

  Patent outcomesUS 10,015,413 mixed
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,015,413
• Apple Inc. v. Resonant Systems, Inc.Some claims unpatentable
  PTAB · Oct 9, 2025 · IPR2024-00806 · APJ Norman H Beamer · IPR · Final written decision

  Claims 1–8, 15–17, and 20 are unpatentable under § 103; claims 14 and 19 were not shown unpatentable because the proposed paramagnetic flux paths in Wakuda lacked adequate support.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Petitioner’s expert declarant contends that person of ordinary skill in the art (POSITA) would have had a degree in mechanical engineering, electrical engineering, physics, or a related technical field, and at least 2–3 years of experience related to the design or development of systems incorporating linear actuators; additional years of experience could substitute for the advanced-level degree. Ex. 1003 ¶ 33. Patent Owner offers “a similar level of ordinary skill in the art.” PO Resp. 3. Based on a review of the record, we adopt Petitioner’s proposed level of ordinary skill in the art because it is consistent with the evidence of record, including the asserted prior art and ’830 patent specification.” slip op. at 11

  • Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)§112(f) appliesDecided for petitioner

    “The parties agree that independent claims 1, 19, and 20 include means plus function limitations under 35 U.S.C. § 112 ¶ 6.8 Pet. 3–7; PO Resp. 6–14. An element in a claim for a combination may be expressed as a means . . . for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. 35 U.S.C. § 112 ¶ 6. In particular, the parties agree that the “driving component” and “control component” requirements of independent claims 1, 19, and 20 are means plus function limitations. Pet. 3–7; PO Resp. 6–14. Construing a means plus function limitation under 35 U.S.C. § 112 ¶ 6 involves two steps: 1) identifying the claimed function and 2) identifying in the specification the corresponding structure that performs the claimed function. Med. Instrumentation & Diagnostics Corp. v. Elekta AB, 344 F.3d 1205, 1210 (Fed. Cir. 2003); Cardiac Pacemakers, Inc. v. St. Jude Med., Inc., 296 F.3d 1106, 1119 (Fed. Cir. 2002).” slip op. at 12

  • Claim Construction › Functional claiming / §112(f) means-plus-function › Corresponding structure / algorithm (indefinite if none)Term construed board ownDecided for petitioner

    “Therefore, the specification clearly links the function of “control[ing] supply of power from the power supply to . . . cause the moveable component to oscillate at a frequency . . . specified by one or more stored values” at least to portions of steps 706 and 708 of the flow diagram algorithm of Figure 7A, as described above. Thus, the control component requires a microprocessor and memory with algorithmic structure including a timing algorithm or similar coding for creating a control output signal that flips to control the direction of current flow through a coil (e.g., coil 514, Fig. 5, coil 626, Fig. 6), where the coil is structure that corresponds to the recited “driving component,” as noted above.11 We adopt the District Court’s conclusion in the Apple litigation that the “control component” structure itself does not require an H-bridge switch, but only requires that the processor generates the “d” inputs to the switch; and further that the structure does not require does not require computing initial default values as specified in step 702 of Figure 7A (i.e., values not specified by a user). Ex. 3001, 30–33, 35. This is in accord with settled law 11 “Rather than using a formal timer mechanism, certain implementations may simply employ counted loops or other simple programming techniques for periodically carrying out tasks.” Ex. 1001, 7:17–20. that limits the structure to that necessary to perform the claimed function. 12 By the same token, we modify the District Court’s construction to the extent it would require, based on such steps as 706, 710, and 716, a specific order of the steps of generating the “p” and “d” values. The claims only require the control component to control the power supply to cause oscillation at a specified frequency and amplitude, but do not require the frequency value to be generated before the amplitude value, or vice versa.” slip op. at 18

  • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner

    “to include the ability disclosed in Ramsay to allow a user to customize and store parameters associated with haptic effects, such as creating “haptic track files” that specify variations in the amplitude and frequency of the effect over time to achieve a desired effect. Pet. 46–47 (citing Ex. 1006 ¶¶ 15, 25– 28, 37; Ex. 1003 ¶¶ 192–193). Petitioner argues that this combination would have been motivated by the desire to expand the functionalities of haptic devices to allow end users to create and customize haptic effects, to provide a fuller haptic experience, and to be able to store haptic effects to save processing power compared to real-time generated effects. Id. at 47–49 (citing Ex. 1006 ¶¶ 14–15, 30, 47, 53–57; Ex. 1003 ¶¶ 194–196). Petitioner argues that this making combination would have had a reasonable expectation of success given that both references deal with linear actuators, both disclose storing frequency and amplitude values, and the combination involves routine knowledge of software techniques. Id. at 49–50 (citing Ex. 1004, 2:3–9; Ex. 1006 ¶¶ 17, 26–28; Ex. 1003 ¶¶ 197–198). Petitioner further argues that it would have been obvious to use the H-bridge switch of Rossi as part of the Gregorio actuator drive circuit 16 in the asserted Gregorio-Ramsay combination to periodically switch the polarity of drive signals to electric coil 28 of Gregorio, and thus oscillate magnet 27, under the control of a signal from processor 12 of Gregorio. Pet. 56 (citing Ex. 1003 ¶ 211). Petitioner argues that this combination would have been motivated because Gregorio does not disclose implementation details and therefore one of ordinary skill would have looked toward teachings like Rossi to fill in those details, and that an H-bridge switch was a well-known example circuit for implementing a change in “current flow direction/polarity” for “push” and “pull” actions in a system, and was a simple, cost-effective, and reliable circuit design. Id. at 56–58 (citing Ex. 1020, Abstr., Figs. 4, 6, 1:65–3:54; Ex. 1003 ¶¶ 212–217). Petitioner argues that making this combination would have had a reasonable expectation of success given that it involved known techniques through routine circuit design considerations and software instructions for generating the control signal. Id. at 58 (citing Ex. 1003 ¶ 218). Petitioner further argues that it would have been obvious to modify the Gregorio-Ramsay-Rossi combination, using the control algorithm disclosed in Aldrich, to replace the monitoring technique of Gregorio with that of Aldrich to maintain a resonance frequency by incrementing or decrementing the drive frequency. Pet. 58–59 (citing Ex. 1004, 4:22–28, 4:42–48; Ex. 1021, 2; Ex. 1003 ¶ 219). Petitioner’s expert provides implementation details of Aldrich, including that the Aldrich hill-climb technique would use a Boolean value to indicate whether the frequency was being increased, with local variables set to default values, and use integer values when processing sensor signals. Id. at 59–60 (citing Ex. 1021, 2; Ex. 1003 ¶¶ 220–222). Petitioner argues that these modifications would have been motivated to improve the Gregorio system using the Aldrich feedback algorithm for targeting a resonant frequency, given that the Gregorio approach had shortcomings that required a monitoring period with reduced haptic feedback, receiving weak EMF signals. Id. at 61–62 (citing Ex. 2004, 3:65–5:55, 5:63–65; Ex. 1021, 1–3; Ex. 1003 ¶¶ 223–227). Petitioner argues that making this combination would have had a reasonable expectation of success given that it involved known techniques for improvement to yield predictable results, readily implemented via software executed by the microprocessor. Id. at 62–63 (citing Ex. 2004, 2:44–50; Ex. 1021, 2; Ex. 1003 ¶ 229). Patent Owner does not address Petitioner’s arguments regarding the” slip op. at 27

  Patent outcomesUS 9,941,830 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 9,941,830
• Intel Corporation v. Telefonaktiebolaget LM Ericsson (Publ)Some claims unpatentable
  PTAB · Oct 8, 2025 · IPR2024-00728 · APJ Russell E Cass · IPR · Final written decision

  Claims 1–5, 7, 8, 10–15, and 17–19 are unpatentable as obvious; claims 6, 9, and 16 are not shown unpatentable because the Midya-based grounds fail on the terminal limitation.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Based on the full trial record, we continue to adopt Petitioner’s definition of the level of ordinary skill in the art, which is consistent with the ’430 patent and the prior art. In adopting this definition, we note that neither the title nor the “Field of the Invention” portions of the ’430 patent limit the invention to integrated circuits, and Patent Owner does not dispute that claim 1 encompasses inductors that are not provided on an integrated circuit. Ex. 1001, code (54), 1:16–22. Additionally, Dr. Prucnal’s definitions have shifted, and his latest definition purports to be based on Dr. Tentzeris’s characterization of the level of ordinary skill, but changes “experience designing integrated circuits or inductors for semiconductors” to “experience designing integrated circuits and inductors for semiconductors” without sufficient explanation of the reasons for the change. Supp. Prucnal Decl. ¶ 8; Reply Tentzeris Decl. ¶ 56. However, our Decision in this case would not change under Patent Owner’s revised articulation. See Reply Tentzeris Decl. ¶ 57 (stating that his opinion would not change under Patent Owner’s revised definition of the level of ordinary skill).” slip op. at 9

  • Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble not limitingDecided for petitioner

    “After considering the full trial record, we agree with Petitioner that the phrase “on a semiconductor die” in the preamble of claim 11 is not limiting. First, we determine that the phrase “on a semiconductor die” in claim 11 does not provide antecedent basis for terms in the body of the claim. The body of claim 11 does not refer to “the semiconductor die” or even mention the “semiconductor die” at all, and neither do any of the claims that depend from claim 11. We disagree with Patent Owner’s argument that the phrase “on a semiconductor die” in the preamble of claim 11 provides antecedent basis for the term “the first inductor” in the body of the claim, because the “first inductor” language in the preamble provides antecedent basis for “the first inductor” language in the claim’s body. The “on a semiconductor die” language in the preamble is presented separately and can be easily parsed from the preamble’s language reciting a “first inductor” without impacting the understandability or grammatical completeness of claim 11. Therefore, the “on a semiconductor die” language in claim 11’s preamble is not necessary to provide antecedent basis for the phrase “the first inductor” in the body of claim 11. This use of language in claim 11 is distinguishable from the Federal Circuit’s opinion in Deere v. Bush Hog, cited by Patent Owner, where the preamble term “rotary cutter deck” provided antecedent basis for the term “said deck” recited in the claim body, because in Deere, the words “rotary cutter” appeared directly before, directly modified, and were not easily parsed from the term “deck.” See Deere & Co. v. Bush Hog, LLC, 703 F.3d 1349, 1357–58 (Fed. Cir. 2012); PO Resp. 7–8.” slip op. at 12

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for patent owner

    “We agree with Petitioner that claims 1 and 11 do not require that the first and second inductor be laterally spaced, but instead merely require that the second inductor be positioned at a “predetermined distance” from the first inductor. Nothing in the claim language restricts this “predetermined distance” from being in the X, Y, or Z direction, or requires that the inductors be laterally spaced in the same plane. Moreover, the fact that the ’430 patent Specification describes embodiments where the inductors are laterally spaced in the same plane does not limit the claims to those embodiments. As explained previously, our reviewing court “has expressly rejected the contention that if a patent describes only a single embodiment, the claims of the patent must be construed as being limited to that embodiment.” Liebel-Flarsheim, 358 F.3d at 906. “Even when the specification describes only a single embodiment, the claims of the patent will not be read restrictively unless the patentee has demonstrated a clear intention to limit the claim scope using ‘words or expressions of manifest exclusion or restriction.’” Id. We see no such “words or expressions of manifest exclusion or restriction” here. Accordingly, we give the term “predetermined distance” its ordinary meaning, which includes a distance in any direction. The parties do not dispute that Taniguchi’s inductors are spaced apart with an insulation layer in between. Therefore, under the ordinary meaning of the claim language, Taniguchi’s second inductor is “positioned at a predetermined distance from the first inductor.”” slip op. at 26

  • Prior constructionPrior construction adoptedDecided for patent owner

    “We agree with and adopt the ITC’s construction of “closely spaced,” which is “two terminals in proximity to each other (such that the electromagnetic field at a certain distance from the first inductor (where the second inductor is positioned) is reduced.” Ex. 1020, 12. We find that this construction is supported by the intrinsic record, including the Specification of the ’430 patent, which shows terminals being “closely spaced” compared to the dimensions of the inductor itself, and explains that the purpose of the close spacing is to make the field contributions from the two parts of the inductor identical. See Ex. 1005, Figs. 1–2, 4:28–32. Claims 1 and 11 of the ’430 patent lack specific dimensions for either the inductor or the spacing between the terminals, and indicate that the purpose of the close spacing is to “minimiz[e] magnetic field contributions from the terminals.” Ex. 1001, 10:22–25, 11:7–10. Dr. Prucnal’s ITC declaration, although not intrinsic evidence, further supports our conclusion. Although Patent Owner does not propose a construction for “closely spaced terminals,” it appears to argue that this term must be interpreted based on the dimensions of the semiconductor chip described in the ’430 patent. PO Resp. 43. We do not see any basis in the intrinsic or extrinsic evidence to impart such a narrow reading to the claim language, particularly because the ’430 patent Specification does not define the “closely spaced terminals” in relation to a semiconductor chip, and claim 1 is not limited to inductors on a semiconductor chip.” slip op. at 40

  Patent outcomesUS 7,151,430 mixed
  Claim construction§ 103 obviousnesscites KSR · Graham
  Patents in suitUS 7,151,430
• LG Electronics, Inc. / LG Electronics U.S.A., Inc. et al. v. Multimedia Technologies Pte. Ltd.Some claims unpatentable
  PTAB · May 19, 2025 · IPR2024-00699 · APJ St John Courtenay III · IPR · Final written decision

  Claims 1, 2, 6–11, and 14–18 are unpatentable under § 103; claims 3–5, 12, and 13 were not shown unpatentable.

  RulingsFinal written decision

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “contends that an ordinarily skilled artisan for the ’805 patent “would have been someone knowledgeable about and familiar with the television display technology that is pertinent to the ’805 patent. A POSITA would have had a bachelor’s degree in Electrical Engineering, Software Engineering, or Computer Engineering, or equivalent training, and approximately two years of experience working in the field of television systems and networking, human-computer interaction, or related technologies. Lack of work experience can be remedied by additional education, and vice versa.” Pet. 9 (citing Ex. 1003 ¶¶ 18–20). In its Preliminary Response Patent Owner indicated it “adopts Petitioner’s definition of a person of ordinary skill in the art (‘POSITA’) for the purposes of [its] Preliminary Response.” Prelim. Resp. 28. We note Patent Owner does not dispute or otherwise disavow Petitioner’s definition of a POSITA in its Response or Sur-reply. See generally PO Resp.; PO Surreply. level of ordinary skill in the art. On the present record, we are satisfied that this definition comports with the level of skill necessary to understand and implement the teachings of the ’805 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (explaining that the prior art itself can reflect appropriate level of ordinary skill in art).” slip op. at 10

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

    “We disagree with Patent Owner. Id. We see nothing in the preamble 1.0, or “receiving” step 1.1.1, or “wherein” clause 1.1.2 that defines a data format prior to organizing step 1.2.1, and we decline to read limitations from the specification into the claim, i.e., a “pre-defined format” being defined prior to organizing step 1.2.1, as argued by Patent Owner. 5 PO Resp. 20. Preamble 1.0 is silent regarding any mention of a data format: “A method of providing content for a television (TV), the method comprising: . . . .” Although step 1.1.1 requires “receiving, by a processor, data relevant to one or more scheduled events from one of a corresponding subservice of a plurality of subservices,” at best this merely requires a type of data that is “relevant to one or more scheduled events” and does not require a particular data format to be used for “data relevant to one or more scheduled events,” nor the “pre-defined” format argued by Patent Owner. PO Resp. 20–21. (emphases added). Nor do we read step 1.1.2 as defining a particular data format used by the three recited types of subservices: “[1.1.2] wherein the plurality of subservices comprises a video-on-demand (VOD) subservice, electronic programming guide (EPG) subservice, and a media subservice.” 5 We emphasize that patentability is based upon the claims. “It is the claims that measure the invention.” SRI Int’l v. Matsushita Elec. Corp. of America, 775 F.2d 1107, 1121 (Fed. Cir. 1985) (en banc). A basic canon of claim construction is that one may not read a limitation into a claim from the written description. Renishaw PLC v. Marposs Societa' per Azioni, 158 F.3d 1243, 1248 (Fed. Cir. 1998). according to a pre-defined format corresponding to each of the plurality of subservices.” (emphases added). However, we find Patent Owner’s contention unavailing that the term “pre-defined format” recited in step 1.2.1 requires three different data model pre-defined formats because claim 1 is silent regarding the argued term “different.” See PO Sur-reply 9 (regarding Patent Owner’s response to the question of “whether element [1.2.1] and the term ‘pre-defined format’ requires three different data models.” Patent Owner responds: “For the above reasons, they do.”). Moreover, we note the term “data model” is not introduced until subsequent “wherein” clause 1.2.2, which merely requires that “the predefined format comprises one of a VOD data model, an EPG data model and a media data model.” (emphasis added).” slip op. at 20

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

    “Regarding the claim 1 term “uniform format” Petitioner replies that Patent Owner “does not dispute that the prior art teaches a ‘uniform format’” in step 1.2.4. Pet. Reply 8 (citing generally PO Resp.). Therefore, Petitioner argues “for the purposes of this proceeding, the term “uniform format” does not require express construction.” Pet. Reply 8 (citing Nidec (Fed. Cir. 2017)). Nevertheless, at the Board’s request (Dec. 29), Petitioner proceeds to address the scope of the claim 1 term “uniform format.” Pet. Reply 8. Petitioner notes that the ’805 patent uses the term “uniform format” in column 33: “The data models provide uniform formats for the respective subservices (i.e., VOD subservice 1420, EPG subservice 1424, and media subservice 1428) and/or the internal content provider modules 1416 which interface with applications 416.” Pet. Reply 8 (quoting Ex.1001, 33:25–30). Petitioner further notes that Dr. Lippmann explains, “the ’805 patent does not appear to ascribe any specific meaning to the term ‘uniform format’ and the passage does not limit the scope of this term to require a plurality of uniform formats.” Pet. Reply (quoting Ex. 1020 ¶ 13).” slip op. at 22

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

    “Patent Owner’s arguments are not persuasive because on January 14, 2025, the Federal Circuit in Lynk Labs Inc. v. Samsung Electronics Co. Ltd., (125 F.4th 1120, 1132 (Fed. Cir. 2025)) held that Title 35 U.S.C. sections “311(b) and 102(e)(1) permit IPR challenges based upon published patent applications, and such published patent applications can be deemed prior art in IPRs as of their filing date.” (emphasis added). Accordingly, we conclude both Melnychenko and Choi are prior art for the purpose of this IPR pursuant to 35 U.S.C. § 311(b) under the holding of Lynk Labs.” slip op. at 6

  Patent outcomesUS 10,419,805 mixed
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,419,805
• LG Electronics, Inc. / LG Electronics U.S.A., Inc. et al. v. Multimedia Technologies Pte. Ltd.Some claims unpatentable
  PTAB · May 19, 2025 · IPR2024-00354 · APJ St John Courtenay III · IPR · Final written decision

  Claims 1, 2, 6–11, and 14–18 are unpatentable as obvious; claims 3–5, 12, and 13 were not shown unpatentable.

  RulingsFinal written decision

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

    “Patent Owner’s arguments are not persuasive because on January 14, 2025, the Federal Circuit in Lynk Labs Inc. v. Samsung Electronics Co. Ltd., (125 F.4th 1120, 1132 (Fed. Cir. 2025)) held that Title 35 U.S.C. sections “311(b) and 102(e)(1) permit IPR challenges based upon published patent applications, and such published patent applications can be deemed prior art in IPRs as of their filing date.” (emphasis added). Accordingly, we conclude both Melnychenko and Choi are prior art for the purpose of this IPR pursuant to 35 U.S.C. § 311(b) under the holding of Lynk Labs.” slip op. at 6

  • Skill levelSkill level petitioner adoptedDecided for patent owner

    “Relying upon the declaration testimony of Dr. Lippman, Petitioner contends that an ordinarily skilled artisan for the ’805 patent “would have been someone knowledgeable about and familiar with the television display technology that is pertinent to the ’805 patent. A POSITA would have had a bachelor’s degree in Electrical Engineering, Software Engineering, or Computer Engineering, or equivalent training, and approximately two years of experience working in the field of television systems and networking, human-computer interaction, or related technologies. Lack of work experience can be remedied by additional education, and vice versa.” Pet. 9 (citing Ex. 1003 ¶¶ 18–20). In its Preliminary Response Patent Owner indicated it “adopts Petitioner’s definition of a person of ordinary skill in the art (‘POSITA’) for the purposes of [its] Preliminary Response.” Prelim. Resp. 28. We note Patent Owner does not dispute or otherwise disavow Petitioner’s definition of a POSITA in its Response or Sur-reply. See generally PO Resp.; PO Surreply. level of ordinary skill in the art. On the present record, we are satisfied that this definition comports with the level of skill necessary to understand and implement the teachings of the ’805 patent and the asserted prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (explaining that the prior art itself can reflect appropriate level of ordinary skill in art).” slip op. at 10

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

    “We disagree with Patent Owner. Id. We see nothing in the preamble 1.0, or “receiving” step 1.1.1, or “wherein” clause 1.1.2 that defines a data format prior to organizing step 1.2.1, and we decline to read limitations from the specification into the claim, i.e., a “pre-defined format” being defined prior to organizing step 1.2.1, as argued by Patent Owner. 5 PO Resp. 20. Preamble 1.0 is silent regarding any mention of a data format: “A method of providing content for a television (TV), the method comprising: . . . .” Although step 1.1.1 requires “receiving, by a processor, data relevant to one or more scheduled events from one of a corresponding subservice of a plurality of subservices,” at best this merely requires a type of data that is “relevant to one or more scheduled events” and does not require a particular data format to be used for “data relevant to one or more scheduled events,” nor the “pre-defined” format argued by Patent Owner. PO Resp. 20–21. (emphases added). Nor do we read step 1.1.2 as defining a particular data format used by the three recited types of subservices: “[1.1.2] wherein the plurality of subservices comprises a video-on-demand (VOD) subservice, electronic programming guide (EPG) subservice, and a media subservice.” 5 We emphasize that patentability is based upon the claims. “It is the claims that measure the invention.” SRI Int’l v. Matsushita Elec. Corp. of America, 775 F.2d 1107, 1121 (Fed. Cir. 1985) (en banc). A basic canon of claim construction is that one may not read a limitation into a claim from the written description. Renishaw PLC v. Marposs Societa' per Azioni, 158 F.3d 1243, 1248 (Fed. Cir. 1998). according to a pre-defined format corresponding to each of the plurality of subservices.” (emphases added). However, we find Patent Owner’s contention unavailing that the term “pre-defined format” recited in step 1.2.1 requires three different data model pre-defined formats because claim 1 is silent regarding the argued term “different.” See PO Sur-reply 9 (regarding Patent Owner’s response to the question of “whether element [1.2.1] and the term ‘pre-defined format’ requires three different data models.” Patent Owner responds: “For the above reasons, they do.”). Moreover, we note the term “data model” is not introduced until subsequent “wherein” clause 1.2.2, which merely requires that “the predefined format comprises one of a VOD data model, an EPG data model and a media data model.” (emphasis added).” slip op. at 20

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

    “Regarding the claim 1 term “uniform format” Petitioner replies that Patent Owner “does not dispute that the prior art teaches a ‘uniform format’” in step 1.2.4. Pet. Reply 8 (citing generally PO Resp.). Therefore, Petitioner argues “for the purposes of this proceeding, the term “uniform format” does not require express construction.” Pet. Reply 8 (citing Nidec (Fed. Cir. 2017)). Nevertheless, at the Board’s request (Dec. 29), Petitioner proceeds to address the scope of the claim 1 term “uniform format.” Pet. Reply 8. Petitioner notes that the ’805 patent uses the term “uniform format” in column 33: “The data models provide uniform formats for the respective subservices (i.e., VOD subservice 1420, EPG subservice 1424, and media subservice 1428) and/or the internal content provider modules 1416 which interface with applications 416.” Pet. Reply 8 (quoting Ex.1001, 33:25–30). Petitioner further notes that Dr. Lippmann explains, “the ’805 patent does not appear to ascribe any specific meaning to the term ‘uniform format’ and the passage does not limit the scope of this term to require a plurality of uniform formats.” Pet. Reply (quoting Ex. 1020 ¶ 13). In its Sur-reply, Patent Owner notes that “Petitioners do not appear to” slip op. at 22

  Patent outcomesUS 10,419,805 mixed
  Claim construction§ 102 anticipation§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 10,419,805

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.