Autoliv ASP, Inc. v. Hyundai Mobis Co., Ltd., Case No. 2016-1896 (April 24, 2017) (Non-Precedential) Patent No. 7,614,653

Key points: 

• Appellant may not seek to narrow the application of its preferred construction during Appeal to the Federal Circuit.

Synopsys, Inc. v. ATopTech, Inc. Case No. 2016-1956, 2016-1957 (April 24, 2017) (Non-Precedential) Patent No. 6,567,967

Key point: 

• During appeal, a party cannot argue that a claim is inherently anticipated to support the Board’s conclusion that the reference expressly anticipates a claim, when the Board concluded that the claim was not inherently anticipated.

Skedco Inc. v. Strategic Operations, Inc., Case No. 2016-1349, (April 24, 2017) (Non-Precedential) Patent No. 8,342,852

Key points:

• When the intrinsic record governs the proper construction of a term, the district court’s claim construction findings are reviewed de novo.

Duke University v. BioMarin Pharmaceutical, Inc., Case Nos. 2016-1106 (April 25, 2017) (Non-Precedential) Patent No. 7,056,712

Key point:

• Expert testimony is not necessary to support the Board’s anticipation determination when the disclosures alone were sufficiently clear and on point to constitute substantial evidence supporting the Board’s anticipation findings.

Securus Technologies, Inc. v. Global Tel*Link Corp., Case Nos. 2016-1992, (April 25, 2017) (Non-Precedential) Patent No. 7,860,222

Key point:

• A motion to amend during IPR may be denied if the amendment does not respond to a ground of unpatentability involved in the review.
• While the Board does not need to expound upon its reasoning in great detail in all cases, it must provide some reasoned basis for finding claims obvious to permit meaningful review by the Federal Circuit.

RecogniCorp, LLC, v. Nintendo Co., Ltd., Case No. 2016-1499 (April 28, 2017) (Precedential) (3-0) Patent No. 8,005,303

Key point:

• An abstract idea is not automatically transformed into patent-eligible subject matter by merely adding a mathematical formula or applying the abstract idea with a computer.
• A high-level abstraction interpretation of the claims may be appropriate when the claims are not directed to a method that improves the functioning of a computer.