July 14, 2023

Federal Circuit Summary for Week Ending July 14, 2023

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Axionics, Inc. v. Medtronic, Inc., No. 22-1451 (July 10, 2023) (precedential) (3-0); Patent Nos. 8,626,314; 8,036,756
Key point(s):
  • The claim, rather than the specification, defines the invention whose obviousness is being assessed.
  • A skilled artisan may be motivated to combine particular features of different references to secure some benefits at the expense of others, even when bodily incorporation would be impossible or inadvisable.
In re Float’N’Grill, Inc., No. 22-1438 (July 12, 2022) (precedential) (3-0); Patent No. 9,771,132
Key point(s):
  • Reissue claims broadening a limitation to cover undisclosed alternatives to a particular feature appearing from the face of the original specification to be a necessary, critical, or essential part of the invention, do not meet the original patent requirement of § 251.
Trinity Info Media, LLC v. Covalent, Inc., No. 22-1308 (July 14, 2023) (precedential) (3-0); Patent Nos. 9,087,321; 10,936,685
Key point(s):
  • Claims can be directed to an abstract idea even if the claims require generic computer components or require operations that a human could not perform as quickly as a computer.
SNIPR Technologies Limited v. Rockefeller University, No. 22-1260 (July 14, 2023) (precedential) (3-0); Patent Nos. 10,463,049; 10,506,812; 10,561,148; 10,524,477; 10,582,712
Key point(s):
  • Pure AIA patents may not be part of an interference.

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Eric Moore