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Federal Circuit

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Virtek Vision v. Assembly Guidance Systems — Federal Circuit Reverses PTAB, Holds Mere Knowledge of Prior Art Elements Is Insufficient for Obviousness

The Federal Circuit reversed the PTAB’s obviousness finding against Virtek’s laser-alignment patent, holding that showing a skilled artisan had the knowledge to make a combination is insufficient for motivation to combine — there must also be a reason why they would have done so.

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Chewy v. IBM — Federal Circuit Invalidates Web Advertising Patents Under § 101, Partially Reverses on Infringement

The Federal Circuit affirmed that IBM’s patent claims directed to identifying advertisements based on search queries are abstract ideas ineligible under § 101—using a conventional database to match ads with search results adds no inventive concept—while partially reversing on noninfringement,

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RAI Strategic Holdings v. Philip Morris — Federal Circuit Clarifies Written Description Standard for Claimed Ranges in Predictable Arts

The Federal Circuit vacated the PTAB’s written description rejection of e-cigarette patent claims directed to a heater-length range, holding that in predictable arts a narrower claimed range can be adequately supported by a broader disclosed range without requiring explicit disclosure of the s

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