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Federal Circuit

Federal Circuit
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Axonics v. Medtronic — Federal Circuit Vacates PTAB Obviousness Decision for Applying Overly Narrow Motivation-to-Combine Test

The Federal Circuit vacated the PTAB’s IPR decisions upholding Medtronic’s sacral nerve stimulation patents, finding the Board committed a fundamental error by limiting the motivation-to-combine inquiry to the specific application context of the primary reference rather than the full cla

Federal Circuit
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Inguran v. ABS Global — Federal Circuit Holds Judgment on Direct Infringement Does Not Preclude Later Induced Infringement Suit

The Federal Circuit reversed the dismissal of an induced patent infringement suit on res judicata grounds, holding that a prior judgment on direct infringement claims does not preclude a subsequent suit for induced infringement when the induced infringement claims are based on different operative fa

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Parus Holdings v. Google — Federal Circuit Holds PTAB May Disregard Evidence Incorporated by Reference in Violation of Procedural Rules

The Federal Circuit affirmed PTAB’s decision to disregard Parus Holdings’ evidence in IPR proceedings, holding that a patent owner’s attempt to incorporate arguments by reference through voluminous exhibits violates PTAB procedural rules and the APA does not require the Board to ov

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Yita v. MacNeil IP — Federal Circuit Reverses PTAB’s Reliance on Secondary Considerations Tied Only to Known Prior Art Feature

The Federal Circuit reversed the PTAB’s reliance on commercial success as a secondary consideration of nonobviousness for car floor mat patents, holding that evidence of commercial success must be linked to the claimed combination as a whole, not to a single feature that was already present in

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Sanderling Management v. Snap — Federal Circuit Invalidates Promotional Content Distribution Patents Under § 101

The Federal Circuit affirmed that patents claiming a method for distributing digital promotional content—loading branding images when a user’s GPS location matches a specified geographic area—are directed to the abstract idea of providing information based on meeting a condition, and contain n

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Ironburg Inventions v. Valve Corp. — Federal Circuit Clarifies IPR Estoppel Burden and Affirms Willful Infringement of Game Controller Patent

The Federal Circuit affirmed willful infringement of Ironburg’s video game controller patent by Valve’s Steam Controller, while vacating and clarifying the standard for IPR estoppel — holding that the patent owner, not the petitioner, bears the burden of proving estoppel applies.

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Regents of University of Minnesota v. Gilead Sciences — Federal Circuit Affirms Invalidity of Antiviral Drug Patent for Lack of Written Description

The Federal Circuit affirmed the PTAB’s ruling that the University of Minnesota’s antiviral drug patent—directed to phosphoramidate prodrugs of nucleoside derivatives—lacked adequate written description support for its broad genus claims, because the patent’s specification disclose

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Minerva Surgical v. Hologic — Federal Circuit Holds Trade Show Demonstration of Medical Device Prototype Triggers Public Use Bar

The Federal Circuit affirmed that Minerva Surgical’s demonstration of 15 fully functional endometrial ablation device prototypes at an industry trade show—more than a year before the patent’s priority date—triggered the public use bar of pre-AIA § 102(b) and invalidated the asserted pate

Federal Circuit
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ChromaDex v. Elysium Health — Federal Circuit Holds Isolated Vitamin B3 Supplement Patent Invalid Under § 101

The Federal Circuit affirmed that patent claims directed to isolated nicotinamide riboside (NR)—a form of vitamin B3 found naturally in cow’s milk—are directed to a natural phenomenon and ineligible under § 101, because the claims effectively read on milk with only the isolation step as a diff

Federal Circuit
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Personalized Media Communications v. Apple — Federal Circuit Affirms $308 Million Patent Voided by Prosecution Laches

The Federal Circuit affirmed that Personalized Media Communications’ patent covering digital rights management technology is unenforceable for prosecution laches, voiding a $308 million jury verdict against Apple, after finding PMC engaged in unreasonable and unexplained delays in prosecuting

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