Laboratory Corporation of America Holdings v. Ravgen Inc., Nos. 2023-1342, 2023-1345 (January 6, 2025) (nonprecedential); Patent No. 7,332,277

Key point:

• Generic industry skepticism does not constitute teaching away – the industry concerns must be specific to the claimed subject matter. Even a small impact can constitute teaching away if that impact is negative.

In re Mazed, No. 2024-1756 (January 10, 2025) (nonprecedential); Application No. 16/602,403

Key point:

• In attempting to distinguish prior art references, the applicant must rely on what is actually claimed.

In re Entresto, Nos. 2023-2218, 2023-2220, 2023-2221 (January 10, 2025) (precedential) (3-0); Patent No. 8,101,659

Key point:

• Claims should not be construed to cover or not cover an allegedly infringing product. Rather, claim construction should occur without reference to the allegedly infringing product before infringement is considered.

Sandstrom v. Microsoft Corporation, Nos. 2024-1040, 2024-1179 (January 7, 2025) (nonprecedential); Patent Nos. 9,632,833 and 9,424,090

Key points:

• For obviousness rejections, there is no requirement to show an existing real-world combination of the cited references.
• Arguments against a rejection that are not raised before the Board are forfeited on appeal at the Federal Circuit.

Simpson Strong-Tie Company Inc. v. Columbia Insurance Company, No. 2023-1944 (January 7, 2025) (nonprecedential); Patent No. 11,021,867

Key point:

• A claim term can provide an antecedent for another, different, claim term if a relevant artisan can readily identify the antecedent relationship.
• When the specification describes multiple alternatives to a particular embodiment, that embodiment is not “essential” for purposes of enablement.