Kroy IP Holdings v. Groupon, No. 2023-1359 (February 10, 2025) (precedential) (3-0); Patent No. 6,061,660

Key point:

• Collateral estoppel does not bar a patentee from asserting claims in district court that are different from those previously invalidated in an IPR

In re Raiz, No. 2024-1533 (February 11, 2025) (nonprecedential) Patent App No. 16/536,175

Key point:

• A general-purpose computer without any disclosed algorithm for executing a claimed function does not provide sufficient structure to support a means-plus-function limitation.

Samsung v. Power2B, Inc., No. 2023-1630 (February 12, 2025) (nonprecedential) Patent No. 9,317,170

Key point:

• During claim construction, claim terms should be interpreted in light of the specification and should not be construed to exclude disclosed embodiments unless there is a clear disclaimer or explicit definitional language limiting the claim scope.

U.S. Well Services, LLC v. Stewart, No. 2023-1796 (February 13, 2025) (nonprecedential) Patent No. 10,526,882

Key point:

• Arguments not raised during IPR proceedings are forfeited and cannot be raised for the first time on appeal.

DNA Genotek Inc. v. Spectrum Solutions LLC, No. 2023-2017 (February 14, 2025) (nonprecedential) Patent No. 10,619,187

Key point:

• When construing claim terms, courts may limit claim scope based on consistent descriptions in the specification, intentional omission of embodiments during prosecution, and applicant statements in related proceedings.