Order Regarding Sanctions IPR2014-00739

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Takeaway: The Board may impose sanctions against a party for misconduct, including for failure to comply with an order, abuse of the process, or any other improper use of the proceeding, such as harassment.

In its Order, the Board expunged Paper 12. Also, the Board ordered the inventor (Dr. Louis Sanfilippo) to refrain from contacting Petitioner or anyone associated with Petitioner in connection with this proceeding; that any communication from Patent Owner to Petitioner or its representatives in this proceeding must be signed by Patent Owner’s counsel of record; that Dr. Sanfilippo cannot sign any paper to be filed with the Board in this proceeding (instead, all papers must be signed by Patent Owner’s counsel of record); and that Petitioner is authorized to file a motion for sanctions against Patent Owner. Continue reading

Final Written Decision IPR2013-00452

Takeaway: If a claim is challenged as being anticipated by alleged prior art information under 35 U.S.C. § 102(b), but the Board finds that at best such information may only be entitled to a date that would make it prior art under 35 U.S.C. § 102(a), the Board will deny the proposed § 102(b) challenge and refrain from considering the information under § 102(a).

In its Final Written Decision, the Board held that Petitioner had demonstrated by a preponderance of the evidence that claim 1 of the ’204 patent is unpatentable as anticipated under 35 U.S.C. § 102(b) and as having been obvious under 35 U.S.C. § 103(a). Claim 1 was the only claim challenged in this particular inter partes review proceeding. Continue reading

Denying Institution of Inter Partes Review IPR2014-01095

Takeaway: It is not sufficient to merely demonstrate that each of the components is known in the prior art; a Petitioner must also explain how a person of ordinary skill in the art would combine those components and why such a person would be motivated to do so.

In its Decision, the Board denied institution of inter partes review, finding that Petitioner did not establish a reasonable likelihood of prevailing with respect to any of challenged claims 1-4 of the ’816 Patent.  The ’816 patent relates to a light emitting panel assembly having a light emitting panel member with an input edge that receives light from the light source, and end edge and side edge reflectors. Continue reading

Denying Institution of Covered Business Method Review CBM2014-00149, 150, 151, 153

Takeaway: It is the petitioner’s burden to show standing to institute a covered business method patent review, which includes providing a detailed analysis and explanation of how the claim language recites method steps involving the movement of money or extension of credit in exchange for a product or service.

In its Decision, the Board denied institution of covered business method patent review of all of the challenged claims (claims 1-11) of the ’730 Patent, because Petitioner had not demonstrated that the ’730 Patent is a “covered business method patent” pursuant to the statutory definition in § 18(d)(1) of the AIA. Petitioner had challenged claims 1-11 of the ’730 Patent as unpatentable under 35 U.S.C. §§ 101, 102(b), and 103(a).  The ’730 Patent relates to a method for controlling access to sensitive prescription drug prone to potential abuse or diversion, by utilizing a central pharmacy and database to track all prescriptions for the sensitive drug. Continue reading

Final Written Decision IPR2013-00577

Takeaway: Failing to provide an explicit statement of the relevant level of skill in the art in the petition may not be fatal, particularly where the prior art itself sufficiently reflects the level of skill in the art.

In its Final Written Decision, the Board found that Petitioner established by a preponderance of the evidence that claims 1-5, 9-11, 15-17, 21, and 22 of the ‘573 patent are unpatentable. Continue reading

Decision Denying Institution IPR2014-01205

Takeaway: The Board may deny institution of an obviousness ground of unpatentability that relies entirely upon arguments made in an anticipation ground; it is the petitioner’s burden to establish a likelihood that a claim would have been obvious.

In its Decision, the Board denied institution of inter partes review, finding that the Petition failed to establish a reasonable likelihood of prevailing with respect to any of claims 1-18 under either 35 U.S.C. § 102 or 103. The ‘847 patent “relates to seismic data acquisition, and more particularly to a method and system for transmitting data between multiple remote stations in an array and a data collection station utilizing a linked relay system to communicate therebetween, permitting transmission paths to be altered.” Continue reading

Order Regarding Certificate of Correction IPR2014-00245

Takeaway: When a Patent Owner seeks correction of an error in a patent that is involved in a trial before the Board, a request for a certificate of correction must be accompanied by a motion to file the request.

In its Order, the Board authorized Patent Owner to file a request for certificate of correction to correct a “printing error” in claim 14 of U.S. Patent No. 8,392,684 B2. Continue reading

Final Written Decision IPR2013-00417

Takeaway: A librarian’s testimony based on personal knowledge of library practices as to the publication date of an article could be persuasive evidence to establish the prior art date of a publication.

In its Final Written Decision, the Board granted Patent Owner’s Second Motion to Amend Claims, in which every challenged claim was canceled with the exception of claim 9, and found that Petitioner had established by a preponderance of the evidence that claim 9 is unpatentable. The Board also granted-in-part Patent Owner’s Motion to Exclude Evidence and denied Petitioner’s Motion to Strike. Continue reading

Final Written Decision IPR2013-00402, IPR2013-00403

Takeaway: On a Motion to Amend, Patent Owner bears the burden, by a preponderance of the evidence, to demonstrate the patentability of its proposed substitute claims, taking into account 35 U.S.C. §§ 101 and 112 in addition to 35 U.S.C. §§ 102 and 103 in view of known prior art.

In its Final Written Decisions in two related cases, the Board granted-in-part Patent Owner’s Motions to Amend U.S. Patent Nos. 8,312,226 B2 and 8,370,583 B2.

In IPR2013-00402, the Board granted Patent Owner’s Motion to the extent it requested cancellation of claims 1-12 of the ’226 patent, and with respect to proposed substitute claims 13 and 15. The Board, however, denied Patent Owner’s motion with respect to proposed substitute claims 14 and 16-18. Similarly, in IPR2013-00403, the Board granted Patent Owner’s Motion to the extent it requested cancellation of claims 1–27 of the ’583 patent, and with respect to proposed substitute claims 28 and 30. The Board, however, denied Patent Owner’s motion with respect to proposed substitute claims 29 and 31–33. Continue reading

Instituting Covered Business Method Review CBM2014-00155

Takeaway: A patent is eligible for covered business method review if the subject matter of at least one claim is directed to a covered business method.

In its Decision, the Board is instituting covered business method patent review of certain claims of the ’245 patent based on the following grounds: claims 1-16 as directed to non-statutory subject matter under 35 U.S.C. § 101; claim 12 as indefinite under 35 U.S.C. § 112, second paragraph; claims 1-4 and 6-16 as having been obvious over Murray under 35 U.S.C. § 103(a); claim 5 as having been obvious over the combination of Murray and Con Edison under 35 U.S.C. § 103(a); and claims 1, 2, 5-9, 13, and 14 as having been obvious over the combination of Brewster and Con Edison under 35 U.S.C. § 103(a). The Board denied all other grounds raised in the Petition. Continue reading