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Withdrawal of Petitioner from IPR Proceeding All But Ensures Success in Contingent Motion to Amend

On remand from the Court of Appeals for the Federal Circuit, the Patent Trial and Appeal Board granted patent owner’s motion to amend on the basis that the totality of the record did not demonstrate by a preponderance of the...more

Federal Circuit Decision Clarifies When an ANDA Filer May Appeal an Adverse IPR Ruling

In Amerigen Pharmaceuticals Limited v. UCB Pharma GmbH, generic drug manufacturer Amerigen appealed a decision of the Patent Trial & Appeal Board finding UCB’s patent to certain chemical derivatives of diphenylpropylamines...more

Estoppel Applies to “Known or Used” Prior Art if PTAB Considered Corresponding Written References

A district court in California has granted-in-part a Plaintiff’s motion for summary judgment of no invalidity under 35 U.S.C. § 103 due to inter partes review (IPR) estoppel. During the pendency of the litigation, Defendants...more

A Claimed Parameter Range That Overlaps with Ranges in the Prior Art Creates a Burden-Shifting and Rebuttable Presumption of...

The Federal Circuit has reversed a decision by the Patent Trial and Appeal Board (PTAB) that certain claims of U.S. Patent No. 8,865,921 (the “’921 Patent”) were not shown to be obvious, finding that the PTAB applied the...more

Federal Circuit Dismisses IPR Petitioner’s Appeal of Final Written Decision for Lack of Standing

Earlier this month, the Federal Circuit dismissed for lack of standing an appeal filed by an inter partes review (IPR) petitioner of a final written decision issued by the Patent Trial and Appeal Board (PTAB) that held two...more

References Introduced During IPR Proceeding Not Necessarily New Evidence to Which Patent Owner Had No Opportunity to Respond

On May 14, 2018, the Federal Circuit affirmed the Patent Trial and Appeal Board’s (the “Board”) Final Written Decision in an inter partes review (IPR) proceeding holding all claims of Anacor Pharmaceuticals, Inc.’s (“Anacor”)...more

Swapping Order of References in Non-Instituted Obviousness Combination Does Not Alter Scope of IPR Estoppel

In an April 12, 2018 decision, the District Court for the District of Delaware held that a change in the primary reference of an obviousness combination that was denied institution by the Patent Trial and Appeal Board (PTAB)...more

In Rare Decision, PTAB Grants Request for Rehearing, Reverses its Prior Decision, and Institutes IPR

Requests for rehearing at the Patent Trial and Appeal Board (the “Board”) are not uncommon; however, the Board rarely grants them. One reason for this result is the high standard applied to reverse a prior decision—abuse of...more

Accused Infringer Estopped from Asserting Prior Art Disclosed in Invalidity Contentions

In an order issued on April 4, 2018, Judge Lynn granted plaintiff ZitoVault’s motion for summary judgment under 35 U.S.C. 315(e)(2), holding that defendant IBM is estopped from asserting invalidity defenses based on prior art...more

PTAB Denies Petition to Institute IPR Because Petitioner Failed to Make Threshold Showing That a Reference Was Publicly Accessible...

The Patent Trial and Appeal Board (PTAB) denied Pfizer, Inc.’s (“Petitioner”) petition to institute an inter partes review (IPR) of the sole claim of Biogen Inc.’s (“Patent Owner”) U.S. Patent 8,329,172 (the “’172 Patent”)....more

Recent PTAB Decision Highlights Importance of Secondary Considerations in Obviousness Challenges

Obviousness challenges are popular post-grant challenges before the Patent Trial and Appeal Board (PTAB). Generally, under 35 U.S.C. § 103 (“§ 103”), the courts make legal and factual inquiries into (1) the scope and content...more

PTAB Denies Institution of IPR Based on Petitioner’s Failure to Rebut Strong Evidence of Objective Indicia of Non-Obviousness

Petitioners Praxair Distribution, Inc. and NOxBOX Limited filed petitions requesting inter partes review (IPR) of the claims of four related patents owned by Mallinckrodt Hospital Products IP Ltd. (“Mallinckrodt”). The claims...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

Federal Circuit Reverses PTAB’s Conclusion that Claims Challenged in Reexamination Would Have Been Obvious

Federal Circuit Reverses PTAB’s Conclusion that Claims Challenged in Reexamination Would Have Been Obvious - On August 31, 2016, the Federal Circuit issued a non-precedential opinion reversing a judgment by the Patent...more

Objective Indicia of Non-Obviousness Proffered by Patent Owner Deemed Insufficient to Establish Nexus

A PTAB panel has rejected a patent owner’s evidence of objective indicia of non-obviousness because it lacked the proper nexus with the claimed subject matter. In its brief, the patent owner had argued that praise by others,...more

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