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Patent Claims Applying Machine Learning Methods to New Environment Do Not Withstand § 101 Scrutiny

RECENTIVE ANALYTICS, INC. v. FOX CORP. - Before Dyk, Prost, and Goldberg. Appeal from the United States District Court for the District of Delaware. The Federal Circuit found that claims applying established methods of...more

Equitable Estoppel: Misleading Silence Not Enough Unless It Was Relied on and Caused Prejudice

FRAUNHOFER-GESELLSCHAFT v. SIRIUS XM RADIO INC. - Before Lourie, Dyk, and Reyna. Appeal from the United States District Court for the District of Delaware. The defense of equitable estoppel requires showing that the...more

The Board Must Provide Reasoned Explanation When Discarding Material, Unrebutted Evidence

CQV CO., LTD. v. MERCK PATENT GMBH - Before Cunningham, Chen, and Mayer. Appeal from the Patent Trial and Appeal Board. The Board erred by failing to explain why it discarded material and unrebutted evidence that a reference...more

Where Method Claim Steps Are Connected by “And,” a Covered Method Must Perform Each Step

SIERRA WIRELESS, ULC V. SISVEL S.P.A. Before Moore, Schall, and Taranto. Appeal from the Patent Trial and Appeal Board. The Board erred by finding method-claim steps connected by “and” to be conditional and by never...more

Every Word Counts: Specification Naming Conventions Can Limit Claim Scope

A patent’s specification established a naming convention that applied to terms in the patent’s claims. Microchip Technology filed an IPR, arguing all claims of HD Silicon Solutions’ patent were invalid. The challenged patent...more

A Patent Must Describe What Is Claimed, Not What Infringes

Before Lourie, Prost, and Reyna. Appeal from the U.S. District Court for the District of Delaware. Summary: A patent was not invalid for lack of written description for failing to describe the specific infringing embodiment...more

“Quotation” Letter Found to Constitute Offer Invalidating Patents

CROWN PACKAGING TECHNOLOGY, INC. v. BELVAC PRODUCTION MACHINERY, INC. - Before Dyk, Hughes, and Cunningham.  Appeal from the United States District Court for the Western District of Virginia. Summary:  An offer for sale...more

Combining Abstract Ideas Does Not Make Them Less Abstract

Before Dyk, Reyna, and Stark. Appeal from the United States District Court for the Western District of Texas. Summary: When assessing patent eligibility under 35 U.S.C. § 101, combining two abstract ideas does not make...more

Unclean Hands and Inequitable Conduct: Dishonesty Is Not the Best Policy

Before Reyna, Hughes, and Stark.  Appeal from the Western District of Louisiana. Summary: The district court correctly found unclean hands, but erred by finding no inequitable conduct without addressing the collective weight...more

Exhibit Combustion: Disavowing Contradictory Statements Contained in Complaint Exhibits

HEALTHIER CHOICES MANAGEMENT CORP. V. PHILIP MORRIS USA, INC. Before Taranto, Stoll, and Cunningham. Appeal from the United States District Court for the Northern District of Georgia. Summary: A plaintiff can...more

Claimed Ranges Overlapping the Prior Art Can Lead To Short Patent Shelf-Life

UCB, INC.  v. ACTAVIS LABORATORIES UT, INC. Before Moore, Chen, and Stoll.  Appeal from the U.S. District Court for the District of Delaware. Summary: District court legally erred by applying incorrect anticipation...more

The Patent Ineligibility of Digital Imaging Processing Method Claims

SANDERLING MANAGEMENT LTD. v. SNAP INC. Before Chen, Cunningham, and Stark.  Appeal from the United States District Court for the Central District of California. Summary:  The district court properly found that...more

Incorporation by Reference: Patent Portfolio Builder or Destroyer?

ARBUTUS BIOPHARMA CORPORATION v. MODERNATX, INC. Before Reyna, Schall, and Chen.  Appeal from the Patent Trial and Appeal Board. Summary: Arbutus’ patent was anticipated by an earlier Arbutus patent that incorporated...more

“Filtering” Appropriate Claim Construction Reasoning

SSI TECHS., LLC v. DONGGUAN ZHENGYANG ELECTRONIC MECHANICAL LTD. Before Reyna, Bryson, and Cunningham.  Appeal from the United States District Court for the Western District of Wisconsin. Summary: The district court...more

Result-Oriented Claims Based on Natural Laws Held Invalid Under § 101

AMERICAN AXLE & MANUFACTURING, INC. v. NEAPCO HOLDINGS LLC - Before Dyk, Moore, Taranto. Appeal from the United States District Court for the District of Delaware. Summary: Mechanical method claims involving tuning...more

In Re Oath Holdings Inc.

Federal Circuit Summary - Before Dyk, Reyna, and Taranto, per curiam. Petition for Writ of Mandamus from the District Court for the Eastern District of New York. Summary: In a case pending before TC Heartland was...more

Stone Basket Innovations, LLC v. Cook Medical, LLC

Federal Circuit Summaries - Before PROST, Wallach, and Taranto. Appeal from the Southern District of Indiana. Summary: In determining whether a party’s actions were “exceptional” under Octane Fitness, the District...more

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