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IPR Grounds Doomed for Failure to Show Patent Reference Was Supported by Disclosures in Priority Application

The Patent Trial and Appeal Board has denied institution of an inter partes review, in part because the petitioner failed to show that a key reference qualified as prior art. The PTAB ruled that the petitioner was required to...more

District of Delaware: IPR Estoppel Does Not Apply to Prior-Art Products

A judge in the District of Delaware has ruled that an estoppel under 35 U.S.C. § 315(e)(2) does not apply to prior-art products, even if those products are “cumulative” of prior-art patents or printed publications that were...more

Failure to Identify Prior Art Disclosure of a Limiting Preamble Dooms IPR Petition

The Patent Trial and Appeal Board denied institution of a petition for inter partes review (IPR), in part because an allegedly anticipatory prior art patent lacked an element of what the board determined was a limiting...more

Overlooked PTAB Cases: Raising Nonobviousness Evidence

Objective evidence of nonobviousness traces its roots to 19th century case law from the U.S. Supreme Court. The analysis of such secondary considerations as commercial success, failure of others, and long-felt but...more

N.D. Ill.: Neither Statutory Estoppel nor “Misleading” Statements Regarding Its Scope Sufficient to Knock Out Invalidity Defenses

A district court has ruled that the scope of IPR estoppel under 35 U.S.C. § 315(e)(2) did not apply to invalidity grounds that relied on physical products. The court also declined to apply judicial estoppel, notwithstanding...more

No IPR Estoppel Despite Purportedly “Gratuitous” Inclusion of Physical Device in Invalidity Defenses

A district court has ruled that the statutory estoppel arising from an inter partes review (IPR) proceeding does not apply to anticipation and obviousness defenses that rely significantly on a physical device. The court also...more

PTAB: Patent Owner’s Burden Regarding a Showing of Priority Is Strictly Circumscribed by the Extent of Petitioner’s Challenge in...

A petition for inter partes review (IPR) has been denied because the petitioner failed to rebut the patent owner’s claim of priority raised in its preliminary response. In denying institution, the Patent Trial and Appeal...more

PTAB’s Claim Construction Not Binding on District Court Despite Affirmance by Federal Circuit of PTAB’s Unpatentability...

An accused infringer in a district court case could not take advantage of a prior claim construction ruling from an inter partes review (IPR) proceeding involving unasserted claims of the same patent. The Patent Trial and...more

On Remand, PTAB Reaches Opposite Conclusion and Finds that Patent Owner Successfully Antedated Key Prior Art Reference

In a remanded inter partes review (IPR) proceeding, the Patent Trial and Appeal Board (PTAB) held that Patent Owner Intellectual Ventures II LLC had successfully antedated a prior art reference asserted by Petitioner Motorola...more

Far-Reaching Effect of IPR Estoppel Dooms Invalidity Defense Based on Prior Art Product

Chief Judge Stark granted a patent owner’s motion for summary judgment of inter partes review (IPR) estoppel, holding that obviousness defenses based on a prior art product could not be asserted because a prior art...more

PTAB Casts Doubt on Judicial Estoppel Challenge at Institution Stage of IPR But Does Not Foreclose it for Trial

The Patent Trial and Appeal Board (PTAB) has rejected a patent owner’s argument that judicial estoppel should prevent a petitioner from making obviousness arguments in support of its petition for inter partes review (IPR)....more

Federal Circuit: Time-Bar Challenge to IPR Doomed by Patent Owner’s Conclusory and Newly Raised Arguments

The Federal Circuit rejected a patent owner’s time-bar challenge to an inter partes review (IPR) proceeding, holding that the patent owner failed to provide sufficient details to establish proper service of a complaint for...more

Invalidity Defenses Will Not Be Stricken at Pleading Stage Despite Defendant’s Earlier PGR Petition

A district court has denied a patent owner’s motion to strike wholesale a defendant’s affirmative defense of invalidity. The key issue in the motion to strike was the application of the estoppel provision of 35 U.S.C. §...more

PTAB Strikes from IPR Record References Introduced After Institution that Purportedly Showed State of the Art

The Patent Trial and Appeal Board has granted in part a Patent Owner’s motion to strike Petitioner’s Reply for improperly raising new arguments and citing new evidence. The Board, however, declined to throw out the entirety...more

PTAB Finds Copyright Notice and Catalog Listing Insufficient as Proof of Public Availability

A Patent Trial and Appeal Board (PTAB) panel has denied institution of an inter partes review proceeding because the petitioner did not establish that key references were properly qualified as printed publications under 35...more

Preliminary Injunction Granted Due to Weakened Invalidity Defense in Light of Inter Partes Review Decision

A judge in the Northern District of California has enjoined a group of defendants from selling a laboratory DNA sequencing machine. The plaintiff first asserted the patent against one defendant in litigation in the District...more

IP Newsflash - April 2016

FEDERAL CIRCUIT - Federal Circuit Lacks Authority to Review Denial of Institution of IPR on Some, but Not All, Raised Grounds - In an appeal of a decision by the Patent Trial and Appeal Board (PTAB) denying the...more

IP Newsflash - August 2015 #3

DISTRICT COURT CASES - Attorney’s Fees Awarded Against Plaintiff for Inadequate Pre-Filing Investigation and Meritless Post-Discovery Positions - A judge in the U.S. District Court for the Central District of...more

IP Newsflash - August 2015

DISTRICT COURT CASES - Humanized Antibody Not Found to Infringe Under DOE - A district court judge granted UCB, Inc.’s (plaintiff) motion for summary judgment that its Cimzia® product, a humanized monoclonal...more

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