Utility Patent Cases
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Utility Patent

Federal Circuit
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Pfizer v. Sanofi Pasteur — Federal Circuit Expands Result-Effective Variable Doctrine for Obviousness of Claimed Ranges

The Federal Circuit affirmed obviousness of Pfizer’s pneumococcal vaccine patent, clarifying that the result-effective variable doctrine applies to optimize claim ranges even when the prior art does not disclose an overlapping range — expanding the scope of when routine optimization can render

Federal Circuit
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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

Federal Circuit
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Weber v. Provisur Technologies — Federal Circuit Holds Confidential Operating Manuals Can Be Prior Art Printed Publications

The Federal Circuit reversed the PTAB, holding that operating manuals distributed to a limited number of customers with confidentiality notices still qualify as ‘printed publications’ and prior art under § 102, because the relevant inquiry is whether interested members of the public coul

Federal Circuit
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Roku v. ITC — Federal Circuit Holds Domestic Industry Economic Prong Can Be Satisfied by Investment in Patent-Covered Component Alone

The Federal Circuit affirmed the ITC’s finding that Universal Electronics satisfied the domestic industry requirement under Section 337 based on its investments in QuickSet technology — a patented component integrated into televisions — even though those investments did not cover the entire te

Federal Circuit
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Dexcom v. Abbott Diabetes Care — Federal Circuit Holds Forum Selection Clause Does Not Block IPR After Covenant Period Expires

The Federal Circuit affirmed that a settlement agreement’s forum selection clause requiring patent disputes to be filed in Delaware federal court did not bar Abbott from filing inter partes review petitions after the agreement’s covenant-not-to-challenge period expired—because the agreem

Federal Circuit
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ParkerVision v. Vidal — Federal Circuit Upholds PTAB Claim Construction Based on Inventor Lexicography, Even Where It Conflicts with District Court

The Federal Circuit affirmed the PTAB’s claim construction of ‘storage element’ based on inventor lexicography in an incorporated-by-reference patent, holding that the PTAB is not bound by a conflicting district court construction and that Intel’s reply arguments were proper

Federal Circuit
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Actelion Pharmaceuticals v. Mylan — Federal Circuit Vacates Infringement Judgment, Requires Extrinsic Evidence for pH Claim Construction

The Federal Circuit vacated an infringement judgment in an ANDA case involving pulmonary hypertension drug patents, holding that the district court erred by construing ‘a pH of 13’ based solely on intrinsic evidence when the parties submitted competing extrinsic evidence—including textbo

Federal Circuit
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Finjan v. SonicWall — Federal Circuit Vacates Collateral Estoppel Invalidity, Affirms Non-Infringement on Stipulated Claim Construction

The Federal Circuit vacated an invalidity judgment against Finjan’s cybersecurity patents that had been based on collateral estoppel from a since-vacated case, while affirming non-infringement on claim construction grounds and excluding Finjan’s damages expert for inadequate apportionmen

Federal Circuit
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Sisvel International v. Sierra Wireless — Federal Circuit Clarifies When Expert Testimony Can Establish Structure for Means-Plus-Function Claims

The Federal Circuit held that the PTAB erred in categorically excluding expert testimony on the structure of computer-implemented means-plus-function claim limitations when the specification identifies named software protocols, clarifying a two-track framework for evaluating such claims.

Federal Circuit
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Sisvel International v. Sierra Wireless — Federal Circuit Affirms PTAB’s Denial of Motion to Amend for Broader Substitute Claims

The Federal Circuit affirmed PTAB’s denial of a motion to amend patent claims in IPR, holding that proposed substitute claims were broader than original claims in at least some respects, and that claims broader in any respect cannot be substituted regardless of narrowing in others.

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