ASSA ABLOY AB v. CPC Patent Technologies — Federal Circuit Upholds Biometric Smart-Lock Patents Against IPR Challenge

Background

CPC Patent Technologies Pty Ltd., an Australian company, holds patents on systems for controlling physical and electronic access using biometric signals — think fingerprint-based smart locks. U.S. Patent Nos. 9,665,705 and 9,269,208 describe a system with two modes: an authentication mode (a fingerprint press grants or denies access) and an enrollment mode (an administrator uses a specific sequence of finger presses to register a new authorized user). The system distinguishes between ordinary access attempts and administrator enrollment sequences by the number and duration of finger presses.

ASSA ABLOY — the world’s largest lock and door-opening company, whose brands include HID Global, Master Lock, and many others — filed three inter partes review (IPR) petitions challenging the validity of these patents as obvious over prior art: U.S. Patent No. 6,256,737 (Bianco) combined with a WIPO publication (Mathiassen). The PTAB instituted all three IPRs but ultimately ruled in CPC’s favor, finding ASSA had not proven the enrollment-process claim limitations would have been obvious to a skilled engineer in view of the cited art. ASSA appealed.

The Court’s Holding

The Federal Circuit affirmed on two independent grounds. First, on claim construction, the court upheld the Board’s interpretation of “biometric signal” as meaning “a physical or behavioral biometric attribute” (e.g., a fingerprint), rejecting ASSA’s proposed broader reading of “the input and output of a biometric sensor.” The court found ASSA’s proposed construction would sweep in non-biometric inputs like number sequences, which the specification and claim language do not support. Without that broader construction, ASSA’s obviousness theory — which depended on reading Mathiassen’s teachings as covering enrollment via biometric sequences — collapsed.

Second, the court found ASSA forfeited its alternative argument that Bianco alone (without Mathiassen) rendered the enrollment limitations obvious. ASSA had consistently presented only a Bianco-plus-Mathiassen combination in its IPR petitions; it raised a Bianco-only theory for the first time in supplemental briefing after Director review. Under Federal Circuit precedent requiring petitioners to identify unpatentability grounds with particularity in the initial petition, this late-raised theory was untimely. The court declined to address it.

Key Takeaways

• Claim construction controls IPR outcomes. ASSA’s entire obviousness theory turned on getting the court to adopt a broader claim construction. The Federal Circuit’s refusal to do so doomed the appeal before the prior-art analysis even began.
• IPR petitions must identify every ground with particularity. A petitioner cannot introduce a standalone prior-art ground for the first time in supplemental briefing following Director review. The opportunity to do so was in the petition itself, and once it passed, the theory was waived.
• Biometric lock patents survive a challenge from the industry leader. CPC’s ’705 and ’208 patents — which previously survived a parallel challenge from Apple (affirmed by the Federal Circuit in August 2025) — have now also survived ASSA ABLOY’s IPR challenge. The remaining valid claims cover the combination of biometric authentication with administrator-controlled biometric enrollment.

Why It Matters

Smart-lock technology is embedded in everything from hotel key systems to corporate access control and consumer deadbolts. CPC’s patents sit at the intersection of biometrics and physical access control — a market where ASSA ABLOY, Apple, and other large players have sought to clear the field through IPR challenges. The Federal Circuit’s affirmance, following a similar result against Apple in 2025, suggests CPC’s patent portfolio is durable.

For patent litigators and IPR practitioners, the decision reinforces two practical lessons: (1) invest heavily in claim construction arguments in the petition, because a favorable or unfavorable claim construction will determine whether prior art even matters; and (2) present every invalidity ground, including standalone alternatives, in the petition itself — post-institution supplemental briefing is not a second bite at the apple for raising new theories.