Egenera, Inc. v. Cisco Systems, Inc., No. 2023-1428 (July 7, 2025) (precedential) (3-0); Patent No. 7,231,430

Key point(s):

• When parties present a summary judgment motion as involving factual issues, but it becomes apparent on appeal that the motion actually turned on claim construction, the Federal Circuit will not address the claim construction issue if appellant failed to preserve it in the district court and failed to adequately present it on appeal.
• To uphold a general jury verdict of noninfringement, the Federal Circuit need only find substantial evidence supporting one of multiple alternative grounds for noninfringement presented to the jury.

EcoFactor, Inc. v. Google LLC, Nos. 2024-1367, 2024-1368 (July 8, 2025) (nonprecedential); U.S. Patent No. 8,596,550

Key point(s):

• A reference’s implicit teachings – such as Ehlers’s decision‐making based on “simple comparison” and Wruck’s use of a “delta value” – can render claim limitations obvious when a skilled artisan would understand the underlying meaning of the concepts.
• Motivation to combine prior‐art references need only be supported by the artisan’s ordinary skill and common sense; explicit discussion of every claim term in each reference is not required.

EcoFactor, Inc. v. Google LLC, No. 2024-1027, 2024-1032, 2024-1033 (July 8, 2025) (nonprecedential); Patent Nos. 8,740,100; 8,751,186; 9,194,597

Key point:

• Expert testimony can provide substantial evidence supporting the interpretation of prior art disclosures, particularly regarding how a person of ordinary skill in the art would understand technical features.

Janssen Pharmaceuticals, Inc. v. Teva Pharmaceuticals USA, Inc., No. 2025-1228, 2025-1252 (July 8, 2025) (precedential) (3-0); Patent No. 9,439,906

Key point:

• The overlapping-range presumption of obviousness applies when a challenged claim requires a numerical feature that overlaps with prior art ranges, but the presumption’s applicability depends on the inventive context and underlying factual premises regarding routine optimization.

In re White, No. 2024-1073 (July 10, 2025) (nonprecedential); Trademark Application No. 90755882

Key point(s):

• A mark is merely descriptive, and thus ineligible for registration, if the mark immediately conveys information about a feature, quality, or characteristic of the goods, such as identifying a style of dish with specific ingredients associated with a geographic region.
• Substantial evidence supporting descriptiveness may include third-party recipes and descriptions showing public recognition of the mark as referring to a type of dish, as well