Samsung Electronics Co., Ltd. v. Power2B, Inc., No. 2023-1629 (March 31, 2025) (Nonprecedential); Patent Nos. 8,624,850 and 9,569,093

Key point(s):

• A claim term in the dependent claims can give rise to a presumption that the limitation is not present in the independent claims.
• Repeatedly disclosing embodiments with specific elements in the specification does not justify imposing such a limitation on independent claims lacking the specific elements.

Express Mobile, Inc. v. GoDaddy.com, LLC, No. 2023-2265 (April 2, 2025) (Nonprecedential); Patent Nos. 6,546,397; 7,594,168; 9,063,755; 9,471,287; and 9,9228,044

Key point:

• Claim terms may be interpreted in light of surrounding claim terms and held to the interpretations given to those surrounding claim terms.

In re Forest, No. 2023-1178 (April 3, 2025) (Precedential) (3-0); Patent Application No. 15/391,116

Key point:

• Provisional rights are granted only when a patent would issue with exclusionary rights.

ams-OSRAM USA Inc., v. Renesas Electronics America, Inc., No. 2022-2185, 2022-2186 (April 4, 2025) (Precedential) (3-0);

Key point:

• A trade secret becomes “properly accessible” when it could have been reverse-engineered rather than when it was actually reverse-engineered.