Huang v. Amazon.com, Inc., No. 2024-1428 (January 28, 2025) (nonprecedential); Patent Nos. 6,744,653, 6,999,331, and RE45,259

Key points:

• A complaint alleging patent infringement must provide sufficient specificity to place defendants on notice of accused products.
• Courts may deny leave to amend when a plaintiff repeatedly fails to address deficiencies after being given notice.

Image Processing Techs. LLC v. LG Electronics Inc., No. 2023-2136 (January 29, 2025) (nonprecedential); Patent No. 6,959,293

Key point:

• The court is not limited to a claim construction with a scope that is the same or narrower than the Board’s construction if the Board’s construction is deemed incorrect.

CA, Inc v. Netflix, Inc., Nos. 2023-1768 (January 27, 2025) (nonprecedential); Patent No. 7,103,794

Key point:

• If a motivation to combine references exists, arguing that another reference provides a superior solution that the combination does not undermine the motivation to combine the references.

Laboratory Corporation of America Holdings v. Ravgen, Inc., No. 2023-1517 (January 29, 2025) (nonprecedential); Patent No. 7,727,720

Key point:

• During claim construction, a claim should be interpreted to give effect to all terms in the claim.

Adaptrend, Inc. v. Stewart, No. 2023-1195 (January 28, 2025) (nonprecedential); Trademark Registration No. 5,873,672

Key points:

• A party whose trademark application is refused due to an existing registration has standing to seek cancellation of the registration.
• A party claiming prior use for cancellation under 15 U.S.C. § 1064 does not need to show continuous use.

United States Automobile Association v. PNC Bank N.A., No. 2023-2171 (January 30, 2025) (nonprecedential); Patent No. 10,769,598

Key point:

• To provide a motivation to combine references, the combination need not provide the best solution for obviousness purposes.

United States Automobile Association v. PNC Bank N.A., No. 2023-1920 (January 30, 2025) (nonprecedential); Patent No. 10,769,598

Key point:

• Even if a party argues an alternative claim construction than a construction found by the Board, a patent can still be invalidated as being obvious if a combination of references renders the claim obvious given either claim construction.

In re Gesture Technology Partners, LLC., No. 2024-1038, (January 27, 2025) (nonprecedential); Patent No. 8,878,949

Key point:

• The Federal Circuit reviews the Board’s legal conclusion of obviousness de novo but its factual findings for substantial evidence.

In re Gesture Technology Partners, LLC., No. 2024-1037, (January 27, 2025) (nonprecedential); Patent No. 8,553,079

Key point:

• A narrow construction that precludes a term’s plain meaning should be rejected.

Apple Inc. v. Gesture Technology Partners, LLC, Nos. 23-1501, 2023-1554 (January 27, 2025) (precedential) (3-0); Patent No. 8,878,949

Key points:

• The Patent Trial and Appeal Board has jurisdiction over IPRs concerning expired patents.
• An expert’s cryptic, unsupported statement does not outweigh the plain import of a prior art reference’s disclosure.

Gesture Technology Partners, LLC v. Apple Inc, No. 23-1463 (January 27, 2025) (nonprecedential); Patent No. 8,878,949

Key point:

• The Federal Circuit does not address dependent claims if not independently addressed on appeal.

Regeneron Pharmaceuticals, Inc. v. Formycon AG, Nos. 2024-2009, 2024-2019, 2024-2156 (January 29, 2025) (nonprecedential); Patent No. 11,084,865

Key point:

• Sales in the US through a partner will not prevent personal jurisdiction over a foreign party if the record shows the foreign party had an intention for the partner to make domestic sales.

Regeneron Pharmaceuticals, Inc. v. Samsung Bioepis Co., Ltd., Nos. 2024-1965, 2024-1966, 2024-2082, 2024-2083 (January 29, 2025) (nonprecedential), Patent No. 11,084,865

Key point:

• Double patenting does not arise just because one patent with a broader claim reads on an invention defined by another patent’s narrower claim.