- Askeladden LLC v. Leigh M. RothschildAll claims unpatentablePTAB · Nov 19, 2020 · IPR2019-00856 · APJ Mitchell G Weatherly · IPR · Final written decision
Original claims 3–10, 12, 13, and 20 were canceled; the Board denied the motion to amend because the proposed substitute claims were unpatentable as obvious.
RulingsFinal written decision- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for patent owner
“The claim language itself implies that the financial services provider decides which biometric information is required during the transaction stage because the Decision Limitation is added to element 1F, which is the first step in the transaction stage recited in elements 1F–H. “[I]n assessing definiteness, claims are to be read in light of the patent’s specification and prosecution history.” Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 908 (2014). Patent Owner identifies support for the Decision Limitation in the Specification that favors interpreting the Decision Limitation as occurring during the transaction stage (i.e., during elements 1E–H). Mot. 14–15 (citing Ex. 1001, 9:9–14). The cited portion of the Specification states: “In another embodiment, the financial service provider may have the system set up such that the server 114 queries through the point-of-sale terminal 102 and informs the merchant which biometric identification data is/are required for the desired transaction.” Ex. 1001, 9:9–14 (emphasis added). The plain language of the claim is consistent with our interpretation because it specifies that the biometric data uploaded in element 1E is used to validate and execute “a purchase transaction,” in element 1H (describing the operation of the claimed system during the transaction stage). Based on our review of the Specification and claim language, we conclude that the Decision Limitation is sufficiently definite under 35 U.S.C. § 112, ¶ 2. Based on that review, we also interpret the Decision Limitation to require that the financial services provider informs, through the server, which type(s) of user biometric identification data must be received at the terminal (e.g., a point-of-sale terminal) to validate the transaction. E. WHETHER THE MOTION MEETS THE REQUIREMENTS OF 35 U.S.C. § 316(d) AND 37 C.F.R. § 42.121” slip op. at 15
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“expressly discloses the Decision Limitation. Opp. 19–20. However, Petitioner contends that Ortiz discloses this concept by describing a system in which the user of a point-of-sale terminal is prompted to input at least one biometric attribute that is randomly selected from a database of previously provided (during enrollment) biometric data. Id. at 20 (citing Ex. 1026 ¶¶ 85–87, 90, 91, Figs. 5 (steps 106, 108) 6 (steps 140, 142); Ex. 1027 ¶¶ 38, 39). The security of Ortiz’s systems and methods is enhanced by enabling the system to randomly challenge the user of a point-of-sale terminal at the time of the transaction because an imposter could not know in advance which biometric attribute would be required by the financial service provider to authorize the transaction. Id. (citing Ex. 1026 ¶¶ 23, 87, 96, 97, 141, Figs. 5, 6; Ex. 1027 ¶¶ 40, 41). Petitioner relies on Dr. Alexander’s testimony to support its contention that an ordinarily skilled artisan “recognized the need to verify user authenticity, such as, e.g., at least in the first instance when enrolling initial biometric(s), to prevent imposters from accessing Karthik’s system and uploading his own fraudulent biometric data.” Pet. 26; see also id. at 27 (citing Ex. 1002 ¶¶ 139–141; Ex. 1004, 2:31–36, 3:33–38). Petitioner reasons that an ordinarily skilled artisan would have been motivated to utilize Robinson’s suggestion to use third party biometric data to verify a user with Karthik’s validation procedure because it “would provide additional security against identity theft.” Id. at 27 (citing Ex. 1002 ¶¶ 139–141). Dr. Alexander opines that an ordinarily skilled artisan would have reasonably expected to be able to incorporate Robinson’s use of third party biometric data into Karthik’s user enrollment protocol. Ex. 1002 ¶ 143. Based on Dr. Alexander’s testimony, Petitioner argues that an ordinarily skilled artisan would have found it obvious to modify the systems and methods suggested by the combined teachings of Karthik and Robinson to incorporate Ortiz’s ability for the financial services provider to decide the type of biometric information required for a transaction (i.e., the Decision Limitation). Doing so would “deter attempts to impersonate the legitimate user of a financial services card during the transaction stage.” Opp. 21 (citing Ex. 1027 ¶¶ 41, 42). Dr. Alexander also opines that an ordinarily skilled artisan would have expected to succeed in incorporating Ortiz’s system and method into the combined Karthik/Robinson system and method because doing so “would have only required a financial services provider to implement a program that allows a server to randomly select one or more of the plurality of biometrics enrolled in Karthik’s database, and communicate that selection to, e.g., a point-of-sale terminal for a user to input” and that the “combined methods, systems, and servers [would] work for their intended purpose.” Id. at 21–22 (citing Ex. 1026 ¶ 27; Ex. 1027 ¶ 43). Patent Owner has not provided any countervailing argument or evidence in response to Petitioner’s Opposition. Based on our review of Petitioner’s argument and evidence of record, which we adopt as our own (see In re NuVasive, 841 F.3d 966, 974 (Fed. Cir. 2016)), we determine that Petitioner has demonstrated by a preponderance of evidence that the combined teachings of Karthik, Robinson, and Ortiz render substitute independent claim 1 unpatentable as obvious.” slip op. at 24
- Skill levelSkill level petitioner adoptedDecided for petitioner
“understanding of a person of ordinary skill in the art at the time of the invention. Graham, 383 U.S. at 17. Based on testimony by Peter Alexander, Ph.D., Petitioner contends that an ordinarily skilled artisan as of June 11, 2008, would have either: “(i) a Bachelor-of-Science degree in electrical engineering, computer science, or computer engineering, or equivalent, and at least two years of additional experience in database and networking technology, computer security and/or authentication using biometric data, or (ii) a post-graduate degree in electrical engineering, computer science, or computer engineering, or equivalent.” Pet. 15 (citing Ex. 1002 ¶¶ 14–17). Patent Owner does not contest Petitioner’s position relating to the level of ordinary skill. See generally Mot. We find Petitioner’s description of the ordinary level of skill in the art at the time of the invention to be consistent with the level of skill reflected in the prior art of record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). Accordingly, we adopt and apply the level of ordinary skill proffered by the Petitioner in this proceeding. D. WHETHER THE “DECISION LIMITATION” IS INDEFINITE” slip op. at 12
- PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend, deniedDenied
“Petitioner argues that if Patent Owner were to argue that the Decision Limitation can be met by the financial services provider deciding which biometric information is required for a transaction during the enrollment or transaction stages, then the claims would be unpatentable for lack of written description support in the Specification. Opp. 8. Petitioner concedes that the portion of the Specification relied upon by Patent Owner for support describes making the decision about what biometric information is needed during the transaction stage. Id. at 9. As explained in Part II.D above, we have narrowly interpreted the Decision Limitation to encompass only such decisions. Accordingly, Petitioner does not persuade us that the Specification fails to provide the required written description for the Decision Limitation as we have interpreted it. Additionally, we conclude that Patent Owner has established that the Specification meets the written description requirement for the Decision Limitation. F. PROPOSED SUBSTITUTE CLAIMS 3–10, 12, AND 13: OBVIOUSNESS IN VIEW OF KARTHIK, ROBSINSON, ORTIZ, AND ONE OF LYON, CARTMELL, OR” slip op. at 18
Patent outcomesUS 8,799,088 unpatentableClaim construction§ 103 obviousnesscites GrahamPatents in suitUS 8,799,088 - Askeladden LLC v. Leigh M. RothschildAll claims unpatentablePTAB · Nov 19, 2020 · IPR2019-00855 · APJ Mitchell G Weatherly · IPR · Final written decision
The Board canceled original claims 1, 2, 11, 14–19, and 21 and denied the motion to amend because the proposed substitute claims were obvious over Karthik, Robinson, and Ortiz.
RulingsFinal written decision- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed board ownDecided for petitioner
“The claim language itself implies that the financial services provider decides which biometric information is required during the enrollment stage because the Decision Limitation is added to element 17A, which is the first step in the enrollment stage recited in elements 17A–D. However, “in assessing definiteness, claims are to be read in light of the patent’s specification and prosecution history.” Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 908 (2014). Patent Owner identifies support for the Decision Limitation in the Specification that favors interpreting the Decision Limitation as occurring during the transaction stage (i.e., during elements 17E–G). Mot. 14–15 (citing Ex. 1001, 9:9–14). The cited portion of the Specification states: “In another embodiment, the financial service provider may have the system set up such that the server 114 queries through the point-of-sale terminal 102 and informs the merchant which biometric identification data is/are required for the desired transaction.” Ex. 1001, 9:9–14 (emphasis added). The plain language of the claim is consistent with our interpretation because it specifies that the biometric data is the data “required for the transaction,” which refers to the “transaction” recited in element 17G (describing the operation of the claimed system during a transaction stage). Based on our review of the Specification and claim language, we conclude that the Decision Limitation is sufficiently definite under 35 U.S.C. § 112, ¶ 2. Based on that review, we also interpret the Decision Limitation to require that the financial services provider informs, through the server, which type(s) of user biometric identification data must be received at the terminal (e.g., a point-of-sale terminal) to validate the transaction. E. WHETHER THE MOTION MEETS THE REQUIREMENTS OF 35 U.S.C. § 316(d) AND 37 C.F.R. § 42.121” slip op. at 14
- Disclosure Requirements (§112) › Definiteness (Nautilus)DefiniteDecided for patent owner
“The claim language itself implies that the financial services provider decides which biometric information is required during the enrollment stage because the Decision Limitation is added to element 17A, which is the first step in the enrollment stage recited in elements 17A–D. However, “in assessing definiteness, claims are to be read in light of the patent’s specification and prosecution history.” Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 908 (2014). Patent Owner identifies support for the Decision Limitation in the Specification that favors interpreting the Decision Limitation as occurring during the transaction stage (i.e., during elements 17E–G). Mot. 14–15 (citing Ex. 1001, 9:9–14). The cited portion of the Specification states: “In another embodiment, the financial service provider may have the system set up such that the server 114 queries through the point-of-sale terminal 102 and informs the merchant which biometric identification data is/are required for the desired transaction.” Ex. 1001, 9:9–14 (emphasis added). The plain language of the claim is consistent with our interpretation because it specifies that the biometric data is the data “required for the transaction,” which refers to the “transaction” recited in element 17G (describing the operation of the claimed system during a transaction stage). Based on our review of the Specification and claim language, we conclude that the Decision Limitation is sufficiently definite under 35 U.S.C. § 112, ¶ 2. Based on that review, we also interpret the Decision Limitation to require that the financial services provider informs, through the server, which type(s) of user biometric identification data must be received at the terminal (e.g., a point-of-sale terminal) to validate the transaction. E. WHETHER THE MOTION MEETS THE REQUIREMENTS OF 35 U.S.C. § 316(d) AND 37 C.F.R. § 42.121” slip op. at 14
- PTAB / AIA Trials › Motions to amend / substitute claimsMotion to amend, deniedDenied
“Petitioner argues that if Patent Owner were to argue that the Decision Limitation can be met by the financial services provider deciding which biometric information is required for a transaction during the enrollment or transaction stages, then the claims would be unpatentable for lack of written description support in the Specification. Opp. 8. Petitioner concedes that the portion of the Specification relied upon by Patent Owner for support describes making the decision about what biometric information is needed during the transaction stage. Id. at 9. As explained in Part II.D above, we have narrowly interpreted the Decision Limitation to encompass only such decisions. Accordingly, Petitioner does not persuade us that the Specification fails to provide the required written description for the 7 Normally, a Patent Owner must identify material in the originally filed application leading to issuance of the patent at issue that supports the proposed amendment. Lectrosonics, Paper 15 at 7. Failing to cite the original disclosure is a basis for denying a motion to amend. Id. However, because Patent Owner appears pro se, we reviewed the original disclosure ourselves to verify that the portion of the Specification cited is identically found in that disclosure. Compare Ex. 1016 ¶ 42, with Ex. 1001, 9:9–14. Accordingly, in this case, we find that Patent Owner’s citation to the Specification functionally refers to material in the original disclosure. Decision Limitation as we have interpreted it. Additionally, we conclude that Patent Owner has established that the Specification meets the written description requirement for the Decision Limitation. F. PROPOSED SUBSTITUTE CLAIMS 1, 2, 11, 14–19, AND 21:” slip op. at 17
- ScopeDecided for patent owner
“3. Whether the Amendments Enlarge the Scope of the Claims An amendment may not enlarge the scope of the claims of the patent. 35 U.S.C. § 316(d)(3); 37 C.F.R. § 42.121(a)(2)(ii). We determine that Patent Owner’s addition of the Decision Limitation narrows the scope of every challenged claim and thus satisfies the prohibition against enlarging the scope of any claim.” slip op. at 16
Patent outcomesUS 8,799,088 unpatentableClaim construction§ 103 obviousness§ 112 disclosurecites Graham · NautilusPatents in suitUS 8,799,088 - Weber, Inc. v. Provisur Technologies, Inc.Rehearing deniedPTAB · Aug 5, 2020 · IPR2019-01463 · APJ Mitchell G Weatherly · IPR · Rehearing
The Board denied Weber’s rehearing request, finding no error or abuse of discretion in denying institution on claims 1–22.
RulingsRehearing decision- RehearingRehearing, deniedDenied
“When rehearing a decision on petition, the Board will review the decision for an abuse of discretion. See 37 C.F.R. § 42.71(c). An abuse of discretion may be determined if a decision is based on an erroneous interpretation of law, if a factual finding is not supported by substantial evidence, or if the decision represents an unreasonable judgment in weighing relevant factors. See Arnold P’ship v. Dudas, 362 F.3d 1338, 1340 (Fed. Cir. 2004). The party challenging the decision has the burden of showing a decision should be modified, and the request for rehearing must specifically identify all matters the party believes the Board misapprehended or overlooked and the place where each matter was previously addressed in its papers. 37 C.F.R. § 42.71(d).” slip op. at 2
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner
“First, the plain language of claim 1 unambiguously recites a causal link between the roller and the movement of the end of the conveying surface of the belt. Specifically, claim 1 recites: “an endless circulating belt having an upper conveying surface.” Ex. 1001, 6:33–34. The claim requires that the belt is “circulated to move [articles] . . . to an end of said conveying surface.” Id. at 6:40–41. The claim recites a “roller” that controls “a belt accumulation region” of the belt. Id. at 6:35–36. The claimed roller must also cause the end of the conveying surface of the belt to move because the “position of said end is moveable . . . by longitudinal positioning of said roller.” Id. at 6:45–49 (emphasis added). The phrase that “end is moveable by longitudinal positioning of said roller” unambiguously requires longitudinally positioning the roller to cause the end of the conveying surface to move. The Specification bolsters our plain reading of claim 1 where it states: “Movement of the pulley 42 controls the extension or retraction of the top region 34, and the position of an end 50 of the top region 34.” Ex. 1001, 4:13–15. Figure 3 (reproduced below) illustrates the manner in which the movement of pulley 42 controls the longitudinal movement of the end 50 of the conveying surface (i.e., top region 34). In the embodiment illustrated below, roller 42 constitutes the claimed roller, top region 34 constitutes the claimed conveying surface, and end 50 constitutes the claimed end of the conveying surface.” slip op. at 4
- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)Institution denied meritsInstitution denied
“an interpretation of “roller.” Patent Owner argued that the roller of claim 1 must both control the accumulation region of the belt and move longitudinally to cause movement of the end of the conveying portion of the belt. Prelim. Resp. 11. Patent Owner conceded that Rheon’s roller 11 met the first requirement of the claimed roller, namely, controlling the accumulation region of the belt. Id. at 23, n.6. However, Patent Owner also argued, id. at 24–26, and we agreed, that movement of Rheon’s roller 11 did not cause movement of the end of the conveying surface, Dec. 8–11. We need not repeat our analysis here because Petitioner identifies no error in our understanding of the manner in which Rheon operates. See Reh’g Req. 11–14 (arguing only errors in our claim interpretation). III. CONCLUSION For the reasons expressed above, we determine that Petitioner has failed to demonstrate error or an abuse of discretion in our Institution Decision. Accordingly, we deny Petitioner’s Request for Rehearing.” slip op. at 6
Claim constructionPatents in suitUS 6,669,005 - Volkswagen Group Of America, Inc. v. Michigan Motor Technologies LLCInstitution deniedPTAB · Jun 2, 2020 · IPR2020-00161 · APJ Sean P O’Hanlon · IPR · Institution
The Board denied institution because Petitioner did not show that the differences between its parallel petitions were sufficiently material to warrant instituting both proceedings.
RulingsInstitution decision- Parallel petitionsInstitution denied discretionary otherDenied
“Based on the Board’s prior experience, one petition should be sufficient to challenge the claims of a patent in most situations. Two or more petitions filed against the same patent at or about the same time . . . may place a substantial and unnecessary burden on the Board and the patent owner and could raise fairness, timing, and efficiency concerns. Consolidated Trial Practice Guide (“CTPG”) 59 (Nov. 2019).2 However, more than one petition may be necessary, for example, “when the patent owner has asserted a large number of claims in litigation or when there is a dispute about priority date requiring arguments under multiple prior art references.” Id.” slip op. at 8
Discretionary denialPatents in suitUS 6,347,680 - Proppant Express Investments, LLC / Proppant Express Solutions, LLC v. Oren Technologies, LLCRehearing grantedPTAB · May 20, 2020 · IPR2017-02103 · APJ Kevin W Cherry · IPR · Rehearing
Petitioner’s rehearing request was granted in part: claims 7, 10, 12, 15, 18, and 19 were held unpatentable; claim 4 was not shown unpatentable.
RulingsRehearing decision- RehearingRehearing, grantedGranted in part
“the burden of showing a decision should be modified, and the request for rehearing must specifically identify all matters the party believes the Board misapprehended or overlooked and the place where each matter was previously addressed in its papers. 37 C.F.R. § 42.71(d). Therefore, Petitioner bears the burden of establishing that we misapprehended or overlooked the matters that it requests that we review.” slip op. at 4
- Expert testimonyPetitioner expert creditedDecided for petitioner
“evidence quantifying how much additional weight Smith’s container could hold if reinforced as Petitioners proposed,” Opp. 3, we also find it unpersuasive. We determine that Dr. Wooley’s testimony, by itself, supports our conclusion that Smith’s container, as Petitioner proposes to modify and combine it with the other pieces of prior art, would meet the “at least 30,000 pounds” limitation. Ex. 1001 ¶¶ 132–141. In this testimony, Dr. Wooley provided a detailed explanation of how much proppant the modified Smith container could hold. See id. We have reviewed that testimony and agree with Dr. Wooley’s conclusion and reasoning. Thus, we disagree with Patent Owner’s argument that Petitioner has failed to provide “any” evidence to support our conclusion that Smith’s modified container can hold “at least 30,000 pounds” as required by claims 4, 7, 10, 12, 15, 18, and 19.” slip op. at 7
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“however, the failure to show the “at least 30,000 pounds” limitation was the sole basis for our finding that Petitioner had failed to prove that claims 7, 10, 12, 15, 18, and 19 were unpatentable. See Final Dec. 33–36, 42–43, 59. We find that the Petitioner has shown all of the limitations of these claims are accounted for in the proposed combinations and that Petitioner has provided an adequate rationale for why a person of ordinary skill would have been motivated to combine the references in the manner proposed with a reasonable expectation of success. See generally Final Dec. (addressing all of Patent Owner’s remaining arguments); Pet. 34–58 (providing mapping for claims 7, 10, 12), 69–70 (claim 15), 79–82 (claims 18 and 19). Accordingly, we modify our Final Decision and find that claims 7, 10, 12, 15, 18, 19 have been shown to be unpatentable.” slip op. at 9
§ 103 obviousnessPatents in suitUS 9,511,929 - Grit Energy Solutions, LLC v. Oren Technologies, LLCRehearing deniedPTAB · Jan 10, 2020 · IPR2017-01917 · APJ Michael L Woods · IPR · Rehearing
The Board denied rehearing and confirmed that claim 13 was not shown unpatentable under §103 because the asserted safety factor was speculative and unsupported.
RulingsRehearing decision- RehearingRehearing, deniedDenied
“the burden of showing a decision should be modified, and the request for rehearing must specifically identify all matters the party believes the Board misapprehended or overlooked and the place where each matter was previously addressed in its papers. 37 C.F.R. § 42.71(d). Therefore, Petitioner bears the burden of establishing that we misapprehended or overlooked the matters that it requests that we review.” slip op. at 3
- Expert testimonyPetitioner expert discountedPatent owner expert creditedDecided for patent owner
“based on speculation and entitled to little weight. See Velander v. Garner, 348 F.3d 1359, 1371 (Fed. Cir. 2003) (according little weight to broad conclusory statements in expert testimony); Gorelik v. Holder, 339 F. App’x 70, 73 (2d Cir. 2009) (noting that “little weight” should be given to an expert’s testimony where the expert’s reasoning is “speculative”); Jenkins v. Astrue, 250 F. App’x 645, 647 (5th Cir. 2007) (holding that “hypothetical testimony” by a vocational expert, which is unsupported by the evidence, may be properly disregarded). Smith is a patent document, not an engineering specification, and does not mention any safety factor, let alone one that is at least 1.15. We credit Mr. Smith’s testimony that confirms this fact. See, e.g., Ex. 2049 ¶ 139 (“Smith is silent about whether his containers are designed with any safety factor, let alone something as specific as Dr. Wooley’s assumed 1.15”) (citing Ex. 2048, 145:25–146:3). Simply because Dr. Wooley testifies that Smith has a safety factor does not make it true. See Trial Practice Guide Update, 5 (August 2018) (“[E]xpert testimony . . . is not a substitute for disclosure in a prior art reference itself.”). We are mindful not to read into Smith that which is not disclosed; such hindsight bias has no role in an obviousness analysis.” slip op. at 7
- Obviousness (§103) › Motivation to combine / reasonable expectation of successNot shown unpatentableNot shown unpatentable
“that Smith’s “sidewalls have a rigidity suitable for retaining no less than about 30,000 pounds of proppant when positioned therein,” as recited in claim 13. Ex. 1002, 10:14–17. “In an [inter partes review], the petitioner has the burden from the onset to show with particularity why the patent it challenges is unpatentable.” Harmonic Inc. v. Avid Tech., Inc., 815 F.3d 1356, 1363 (Fed. Cir. 2016). Petitioner did not meet its burden. In support of its “safety factor” argument, Petitioner relies on Dr. Wooley’s testimony that Smith has a safety factor of at least 1.15. See Pet. 70 (citing in relevant part Ex. 1001 ¶ 181); see also supra Part II.b. Dr. Wooley’s testimony regarding Smith’s safety factor, however, is based on speculation and entitled to little weight. See Velander v. Garner, 348 F.3d 1359, 1371 (Fed. Cir. 2003) (according little weight to broad conclusory statements in expert testimony); Gorelik v. Holder, 339 F. App’x 70, 73 (2d Cir. 2009) (noting that “little weight” should be given to an expert’s testimony where the expert’s reasoning is “speculative”); Jenkins v. Astrue, 250 F. App’x 645, 647 (5th Cir. 2007) (holding that “hypothetical testimony” by a vocational expert, which is unsupported by the evidence, may be properly disregarded). Smith is a patent document, not an engineering specification, and does not mention any safety factor, let alone one that is at least 1.15. We credit Mr. Smith’s testimony that confirms this fact. See, e.g., Ex. 2049 ¶ 139 (“Smith is silent about whether his containers are designed with any safety factor, let alone something as specific as Dr. Wooley’s assumed 1.15”) (citing Ex. 2048, 145:25–146:3). Simply because Dr. Wooley testifies that Smith has a safety factor does not make it true. See Trial Practice Guide Update, 5 (August 2018) (“[E]xpert testimony . . . is not a substitute for disclosure in a prior art reference itself.”). We are mindful not to read into Smith that which is not disclosed; such hindsight bias has no role in an obviousness analysis.” slip op. at 7
§ 103 obviousnessPatents in suitUS 9,296,518
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.