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Limitations Absent from a Notice of Allowability May be Material

On August 24, 2023, USPTO Director Kathi Vidal vacated a PTAB decision denying institution of inter partes review in Keysight Technologies, Inc. v. Centripetal Networks, Inc. and remanded the case for further proceedings. ...more

Defective Service of Complaint Fails to Trigger Time Bar

Institution of an IPR is automatically barred if the “petition requesting the proceeding is filed more than 1 year after the date on which the petitioner…is served with the complaint alleging infringement of the patent.” 35...more

Common Inventorship And Technology Insufficient For 325(d) Denial

The PTAB recently declined to apply Section 325(d) and instituted inter partes review after a patent owner unsuccessfully argued that the petition relied on substantially the same prior art as that which the Office had...more

Petitioner Faulted For Not Preemptively Addressing Fintiv

On July 17, 2023, the Patent Trial and Appeals Board (“PTAB”) exercised its discretion under 35 U.S.C. § 314(a) to deny institution of an inter partes review petition based on the stature of a related U.S. District Court of...more

Explanations, Not Bare Citations, Needed To Establish Prior Art Date

Although provisional applications can be used to secure an earlier date for 102(e), the petitioner bears the burden of production in establishing a prior art date for the asserted prior art. The Patent Trial and Appeal Board...more

Board Denies Follow-On Petition

In recent decision 3M Company v. Bay Materials, the Board denied 3M Company’s (“Petitioner”) second Petition for inter partes review (“Second Petition”) after exercising its discretion under § 314(a) and finding that each of...more

PTAB Denial of Inter Partes Review under §325(d)

The Patent Trial and Appeal Board (“PTAB” or “Board”) recently denied inter partes review (IPR) of an electrocardiography monitor patent under 35 U.S.C. §325(d), finding that the same or substantially the same prior art or...more

Customer/Manufacturer Relationship Insufficient To Bar

Recently, the PTAB held that Samsung Electronics Co. Ltd. (“Petitioner”), met its burden in showing that a third party (the “Third Party”) was neither a real party-in-interest (“RPI”) nor in privity with Petitioner....more

Motion to Amend: Much to Admire?

Motions to amend (MTA) are becoming a more frequently used tool for patent owners litigating before the Patent Trial and Appeal Board (PTAB). When a patent is being challenged in an inter partes review (IPR) or post-grant...more

Likelihood of Success on 1 of 46 Claims Deemed Inefficient

The PTAB recently exercised its discretion under 35 U.S.C. § 314 to deny institution of inter partes review for inefficient use of the PTAB’s time and resources notwithstanding that the petitioner met the threshold for...more

USPTO Requests Comments Regarding Motion to Amend Pilot

The USPTO continues to seek public feedback on PTAB procedures and potential rule changes. In addition to soliciting comments on the many proposed rule changes announced on April 21, 2023, the USPTO also recently issued a...more

Duty of Candor is Not to be Ignored

In a rare exercise of authority, the PTAB issued sanctions against a Patent Owner for failure to meet its duty of candor and good faith by withholding information relevant to the patentability of challenged and substitute...more

VLSI Claims Deemed Unpatentable

On May 12, 2023, the Intel v. VLSI chronicle continued as the PTAB issued a final written decision holding that all of the challenged claims of VLSI’s U.S. Patent No. 7,725,759 (“the ’759 patent”) were unpatentable as...more

PTAB Panel Excuses Late Filings

On May 10, 2023, a PTAB Panel excused the late filings of the Patent Owner and allowed over thirty exhibits and a Corrected Patent Owner Response (“CPOR”) to be submitted into the record in Samsung Electronics Co., Ltd. v....more

PTAB Issues Back-to-Back Fintiv Denials After Dry Spell

The PTAB recently issued back-to-back Fintiv denials. The first denial issued on May 4, 2023. Read here about Samsung Electronics Co. Ltd. v. California Institute of Tech., No. IPR2023-00130, Paper 10 (P.T.A.B. May 4,...more

Proof of Prior Art Requires Sufficient Corroboration By Credible Evidence

Proof of prior art is an issue that often arises in inter partes and post grant review proceedings before the PTAB. In a recent decision, the Federal Circuit explained the quantum of proof that is required to establish prior...more

Limited Stipulation Results In Fintiv Denial

Patent Owner, IP Bridge, filed a patent infringement suit against Petitioner, Ericsson, for infringement of seven of its patents directed at radio communication between a base station and a mobile station and related...more

OpenSky – Director Finds Abuse Of Process

In OpenSky Industries, LLC v. VLSI Technology LLC, Under Secretary of Commerce for Intellectual Property, Katherine Vidal, issued a precedential decision regarding OpenSky’s violation of the Director’s express order and...more

Patent Owner Ordered To Produce Infringement Contentions

On May 3, 2022, a panel of three PTAB administrative patent judges granted a motion for additional discovery in TCL Industries Holdings Co., Ltd. v. Parkervision, Inc., IPR2021-00985, (PTAB 2022), in which the PTAB deemed the...more

Fintiv Denial Despite Stipulation

On May 9, 2022, the Patent Trial and Appeal Board denied Hillman Group, Inc.’s (“Hillman’s”) three petitions for inter partes review. See The Hillman Group, Inc. v. Hy-Ko Products Co. LLC, IPR2022-00168, -00169, and -00174....more

PTAB News and Notes

Within the past few weeks, the PTAB has issued new guidance addressing a number of important issues including the use of applicant admitted prior art, the Director review process, and changes to PTAB hearings going...more

Legislation: PTAB Reform Act of 2022 (UPDATED)

Since the passage of the America Invents Act in 2012, both petitioners and patent owners have expressed concerns regarding the procedures and practices of the Patent Trial and Appeal Board (PTAB). In an effort to respond to...more

Director to Review Institution of Trial Challenging Patents Found Infringed

U.S. Patent and Trademark Office (“USPTO”) Director Vidal is initiating sua sponte review of the Patent Trial and Appeal Board’s (“PTAB”) decisions to institute inter partes review of two patents owned by VLSI Technology LLC,...more

Legislation: PTAB Reform Act of 2022

On June 16, Senators Leahy, Cornyn, and Tillis introduced the PTAB Reform Act of 2022. The full text of the bill is available...more

Coordinate Arguments To Avoid Procedural Bars

In a recent decision, 25 F.4th 1035 (Fed. Cir. 2022), the Federal Circuit dismissed for lack of jurisdiction an appeal of the PTAB’s decision that estopped a Petitioner from maintaining a third IPR that challenged the same...more

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