February 11, 2015

Federal Circuit Court Decisions for the Week Ending February 6, 2015

In re Papst Licensing Digit. Cam. Pat. Lit., No. 2014-1110, Feb. 2, 2015 (precedential) (3-0) (Patents 6,470,399 & 6,895,449)

Key point(s):

  • The Federal Circuit reviews district court claim constructions de novo when intrinsic evidence fully determines the proper claim construction.

Walter J. Beriont., v. GTE Labs, Inc., No. 2014-1424, January 27, 2015 (non-precedential) (Patent 5,920,802)

Key point(s):

  • Inventors listed on an issued patent are presumed correct and complete. Establishing that the listed inventors are incorrect – either with respect to a missing inventor or an incorrectly listed inventor – requires clear and convincing evidence.
  • Uncorroborated testimony of an inventor alleging another listed inventor is not an actual inventor is insufficient to establish inventor misjoinder by clear and convincing evidence.

In re Cuozzo Speed Technologies, LLC., No. 2014-1301, February 4, 2015 (precedential) (2-1) (Patent 6,778,074)

Key point(s):

  • The PTO’s decision to institute (or not) an inter partes review (IPR) cannot be reviewed by the Federal Circuit, even after final determination in the IPR.
  • The PTO’s use of the “broadest reasonable interpretation” standard for interpreting claims during an IPR is not improper. 

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