DivX, LLC v. Unified Patents, LLC, No. 23-1699 (June 24, 2025) (nonprecedential); Patent No. 10,326,987

Key point:

• A combination of references may render a claim obvious under 35 U.S.C. § 103 if it is a suitable combination that teaches the claim—it need not be the best combination.

directPacket Research, Inc. v. Polycom, Inc., No. 24-1147 (June 25, 2025) (nonprecedential); Patent No. 7,773,588

Key points:

• For the Alice inquiry, the purported technological improvement must be present in the claims themselves and recited with sufficient specificity to explain how it is achieved.
• Elements that rely on an abstract idea cannot transform the claims into significantly more than the abstract idea itself.

Golden v. Google LLC, No. 24-2024 (June 25, 2025) (nonprecedential); Patent Nos. 10,163,287, 9,589,439, 9,069,189, 10,984,619

Key points:

• A claim of direct infringement fails if all theories of infringement require that the accused products be modified, such as by using a third-party app or external apparatus.
• A claim for joint infringement fails under Rule 12(b)(6) if the pleading fails to allege facts regarding the defendant’s degree of control or the formation of a joint enterprise.

In re Shafovaloff, No. 24-1035 (June 27, 2025) (nonprecedential); Application No. 15/173,604

Key point:

• When drafting claims, reciting that something can be done in a given way is different from reciting that it must be done that way (in this case, being “positionable” in front of the eye does not mean it must be “positioned” in front of the eye, and being “bendable” is distinct from being “bent”).

Lyft, Inc. v. Quartz Auto Technologies, LLC, No. 24-1089 (June 27, 2025) (nonprecedential); Patent Nos. 6,847,871, 7,958,215

Key points:

• The scope of the claims can be limited by the scope of the specification.
• If terms are repeatedly and consistently used interchangeably in the specification, those interchangeable terms will generally be read into the claims.