Federal Circuit

Federal Circuit patent decisions

Federal Circuit, Utility Patent

Google LLC v. Parus Holdings — Federal Circuit Vacates IPR Decision, Faults PTAB for Analyzing Prior Art in Isolation and for Secret Claim Construction

The Federal Circuit vacated a PTAB decision upholding Parus Holdings’ voice-browsing patent against Google’s IPR challenge, holding that the Board improperly analyzed prior art in isolation rather than in combination, secretly construed a claim term without notice to Google, and failed to explain its inconsistency with earlier IPR rulings on related Parus patents.

Federal Circuit, Utility Patent

Ridge Corp. v. Kirk NationaLease — Federal Circuit Reverses Preliminary Injunction, Finding Substantial Non-Infringement Questions on Three Patent Claim Limitations

The Federal Circuit reversed a preliminary injunction in a patent dispute over insulated truck cargo doors, holding that the accused ‘sandwich’ panel door raised substantial questions of non-infringement under three separate claim limitations and that the patentee failed to show irreparable harm.

Federal Circuit, Patent Subject Matter Eligibility

Dental Monitoring SAS v. Align Technology — Federal Circuit Holds AI-Powered Dental Imaging Patents Ineligible Under § 101

The Federal Circuit affirms invalidation of two Dental Monitoring patents covering deep-learning dental arch image analysis, holding that applying generic machine learning to a new domain — orthodontic imaging — does not supply the “inventive concept” required for patent eligibility under § 101.

Federal Circuit, Patent Subject Matter Eligibility

Etison LLC (ClickFunnels) v. HighLevel — Federal Circuit Affirms Invalidity of Sales Funnel Website Patents Under Alice

The Federal Circuit affirmed that ClickFunnels’ sales-funnel website creation patents are invalid under § 101, holding that the abstract idea of “filtering information based on user preferences” cannot be rescued by conventional template-selection and sequential-webpage features, while also clarifying the burden-shifting framework for representative-claim analysis.

Federal Circuit, Utility Patent

Enanta Pharmaceuticals v. Pfizer — Federal Circuit Kills Paxlovid Patent Over Single-Carbon Priority Gap

The Federal Circuit affirmed invalidation of Enanta’s Paxlovid-related patent because its 2020 provisional application disclosed ‘C2’ alkyl groups while the issued patent claimed ‘C1,’ a difference of one carbon atom that broke the priority chain and exposed the claims to anticipation by Pfizer’s prior disclosure of nirmatrelvir.

Federal Circuit, Utility Patent

PACT XPP Schweiz AG v. Intel — Federal Circuit Affirms Noninfringement on Forfeited Argument and Prosecution Estoppel

The Federal Circuit affirmed Intel’s summary judgment win, finding PACT XPP forfeited its capability-based infringement theory on the ‘301 patent and that prosecution statements during ex parte reexamination narrowed the ‘593 patent’s ‘physically dedicated connection’ claim to exclude Intel’s shared-bus architecture.

Federal Circuit, Utility Patent

Ironburg Inventions v. Valve Corp. — Federal Circuit Again Vacates IPR Estoppel for Insufficient Evidence and Hindsight Bias

The Federal Circuit reversed and remanded a district court’s IPR estoppel ruling for the second time, holding that a classification search returning 26,333 results cannot show a prior art reference was “reasonably discoverable,” and that Cardinal IP’s search evidence for a second invalidity ground was tainted by hindsight bias throughout.

Federal Circuit, Utility Patent

Ironburg Inventions v. Valve Corp. — Federal Circuit Tightens IPR Estoppel Standard, Reverses Both Invalidity Bars

In a precedential decision, the Federal Circuit reversed district court estoppel orders that had blocked Valve from using two prior-art grounds at trial, holding that classification searches returning 26,333 results do not establish discovery and that hindsight-infected forward citation searches cannot prove what a 2016 petitioner reasonably could have raised.

Federal Circuit, Utility Patent

DynaPass IP Holdings v. Bank of America — Federal Circuit Affirms Dismissal on Claim Construction of Two-Factor Authentication Patent

The Federal Circuit affirmed the dismissal of DynaPass’s infringement claim against Bank of America, holding that the claim term ‘receiving the password’ requires the user to submit a pre-combined passcode-and-token password — not submit the two components separately as BofA’s mobile banking app does.

Copyright, Federal Circuit

Aljindi v. United States — Federal Circuit Confirms §1498(b) Is Exclusive Path for Copyright Claims Against the Government

In a nonprecedential ruling, the Federal Circuit affirmed that copyright infringement claims against the U.S. government must proceed exclusively under 28 U.S.C. §1498(b) and cannot be recast as Tucker Act ‘takings’ claims — a ruling arising from a pro se plaintiff’s allegation that the government used his AI dissertation without compensation.

Federal Circuit, Patent Subject Matter Eligibility

AGI SureTrack v. Farmers Edge — Federal Circuit Affirms Farming Data Patents Are Ineligible Under §101 but Reopens Attorney’s Fees Question

The Federal Circuit affirmed that patents claiming automated farming data collection using generic computer components are directed to patent-ineligible abstract ideas under Alice, but vacated the district court’s unexplained denial of attorney’s fees and remanded for further proceedings.

Federal Circuit, Utility Patent

Actelion Pharmaceuticals v. Mylan Pharmaceuticals — Federal Circuit Affirms That pH Claims Require Standard-Temperature Measurement

The Federal Circuit affirmed that Actelion’s patent claims requiring a bulk solution with ‘a pH of 13 or higher’ refer to pH measured at standard temperature (25±2°C), not at the solution’s actual operating temperature, finding no literal or equivalent infringement by Mylan’s generic epoprostenol drug.

Federal Circuit, Utility Patent

Seoul Semiconductor v. Finelite — Federal Circuit Affirms Samsung’s Limited Indemnification in LED Patent Dispute

The Federal Circuit affirmed that Samsung’s 2012 sales agreement with Finelite unambiguously incorporated a full contract of sale that limited Samsung’s indemnification obligations to Hong Kong — where title to LED chips passed — leaving Finelite without indemnity coverage for U.S. patent infringement claims brought by Seoul Semiconductor.

Federal Circuit, Utility Patent

Universal Electronics v. Roku — Federal Circuit Affirms PTAB Finding That Remote Control Patent Claims Are Obvious

The Federal Circuit affirmed the PTAB’s finding that claims of Universal Electronics’ remote control codeset patent (U.S. Patent No. 9,847,083) are unpatentable as obvious, agreeing with the Board’s broad construction of ‘protocol and formatting information’ as ‘information needed to transmit a signal from one device to another in a way that the receiving device can make sense of and use the signal.’

Federal Circuit, International Trade Commission, Utility Patent

BISSELL v. ITC — Federal Circuit Affirms That Redesigned Tineco Vacuums Do Not Infringe, Clarifies Expert Reliance on Discovery Source Code

The Federal Circuit affirmed the ITC’s finding that Tineco’s redesigned wet-dry vacuum cleaners do not infringe BISSELL’s patents, while also establishing that ITC experts may rely on source code produced in discovery but never formally admitted as a hearing exhibit under FRE 703.

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