Motorola Mobility LLC v. Largan Precision Co., No. 2024-1414 (September 15, 2025) (nonprecedential); Patent No. 9,696,519

Key point(s):

• Evidence must show that a POSITA would have been motivated to combine references, not merely that a POSITA could combine references.
• Limiting evidence to only reasonable expectation was harmless error because there was no showing the evidence applied more generally would have altered the outcome.

Ng LLC v. CreatedHair Designs, LLC, No. 2024-1599, (September 16, 2025) (nonprecedential) Patent Nos. 10,945,477 & 10,881,159

Key point(s):

• A claim construction should not make a limitation meaningless.

In re Butler, No. 2023-2380 (September 17, 2025) (nonprecedential); Patent Application No. 16/891,541

Key point(s):

• A negative limitation that is not mentioned can be supported by a showing that the limitation would always be understood by skilled artisans as being necessarily excluded from the claimed apparatus or method.

Lambeth Magnetic Structures, LLC v. Seagate Technology (US) Holdings Inc., Nos. 2023-1335, 2023-1346 (September 17, 2025) (nonprecedential) Patent No. 7,128,988

Key point(s):

• When the claim recites only purely structural features, a function from the specification should not be incorporated into the claim.