In re Floyd, No. 2023-2395 (April 22, 2025) (nonprecedential); Design App. No. 26/685,345

Key point(s):

• A design application may not claim priority to a utility application if the claimed design lacks written description support in the utility disclosure
• Predictability of the technology embodied in a utility application does not necessarily carry over into the predictability of the designs

Qualcomm, Inc. v. Apple, Inc., Nos. 2023-1208, 2023-1209 (April 23, 2025) (precedential) (3-0); Patent No. 8,063,674

Key point(s):

• A challenge to a determination of whether applicant admitted prior (AAPA) forms the basis of a ground for petition to institute inter partes review (IPR) is a challenge to the manner in which the agency’s review proceeds once instituted and is reviewable.
• 35 U.S.C. § 311(b) is not ipso facto satisfied by a ground that relies on AAPA in combination with prior patents or printed publications.
• Petitioner’s express statements that AAPA is the basis of a ground is dispositive.

Metacel Pharmaceuticals LLC v. Rubicon Research Private Ltd., No. 2023-2386 (April 23, 2025) (nonprecedential); Patent No. 10,610,502

Key point(s):

• A proposed label in an ANDA submission that permits, but does not encourage, an infringing use does not induce infringement.
• Non-public submissions to the FDA cannot induce infringement.

Valve Corporation v. Ironburg Inventions, Inc., No. 2023-1725 (April 23, 2025) (nonprecedential); Patent No. 9,289,688

Key point(s):

• A claim that is adjudicated on appeal is foreclosed due to issue preclusion and collateral estoppel. The preclusion extends to dependent claims that are not patentably distinct from the adjudicated claim.
• Substantial evidence must support Board findings of lack of motivation to combine.

Wakefield v. Blackboard Inc., Nos. 2024-3030 – 2024/3038 (April 23, 2025) (nonprecedential); Patent No. 7,162,696

Key point(s):

• Rule 60(b) relief must be sought within a “reasonable time,” and cannot be used to relitigate issues that were or could have been raised on direct appeal.
• Allegations of judicial misconduct do not automatically justify setting aside a final judgment, especially when not promptly raised.

Epic Games, Inc. v. IngenioShare, LLC, Nos. 2023-2177, 2023-2178, 2023-2179, 2023-2180 (April 24, 2025) (nonprecedential); Patent Nos. 10,142,810, 10,708,727, and 10,492,038

Key point(s):

• A “network-based portal” was construed to reside on the server side of a network, not to include client-side user interfaces.
• Claim construction based on intrinsic evidence and dictionary definitions concluded client-resident interfaces in prior art did not satisfy claim language
• Failure to show that prior art disclosed a server-side network-based portal defeated obviousness challenge.

North Star Technology International Ltd. v. Latham Pool Products, Inc., No. 2023-2138 (April 24, 2025) (nonprecedential); Design Patent No. D791,966

Key point(s):

• Design patent infringement requires substantial similarity in overall appearance, as perceived by an ordinary observer.
• Functional or common design elements do not support a finding of infringement.
• Designs with distinct ornamental features—here, angular versus curved—can be found plainly dissimilar as a matter of law.

MyPAQ Holdings Ltd. v. Samsung Electronics Co., Ltd., Nos. 2023-2024, 2023-2025 (April 24, 2025) (nonprecedential); Patent Nos. 8,477,514; 7,675,759

Key point(s):

• Patentee failed to establish a clear lexicographic definition limiting “core state” to ACPI-defined “C-states.”
• The Board’s findings that the prior art disclosed “core state,” “duty cycle,” and other disputed claim limitations were supported by substantial evidence.
• Expert testimony confirming the operation of power switch timing as a “duty cycle” constituted valid support for an anticipation finding.