Alnylam Pharmaceuticals, Inc. v. Moderna, Inc., No. 2023-2357 (June 4, 2025) (precedential) (3-0); Patent Nos. 11,246,933 and 11,382,979

Key point(s):

• To act as a lexicographer, the definition must be “clearly stated in the patent specification or file history.”
• “[O]nce the high threshold for lexicography is met in a patent,” “a high threshold would have to be met before finding a departure from that controlling definition.”

Apple Inc. v. Gesture Technology Partners, LLC, No. 2023-1494 (June 5, 2025) (nonprecedential); Patent No. 8,194,924

Key point(s):

• Art may be analogous because it is in the “same field of endeavor” or because it is “reasonably pertinent” to the problem being solved.
• Merely identifying alleged overlap between the disclosures is insufficient.

Dolby Laboratories Licensing Corporation v. Unified Patents, LLC, No. 2023-2110 (June 5, 2025) (precedential) (3-0); Patent No. 10,237,577

Key point(s):

• USPTO practice is to only adjudicate real party in interest (RPI) disputes when “material to the proceeding in the interest of cost and efficiency”
• Allegedly failing to name all real parties in interest (RPI) in an inter partes review (IPR) does not grant standing to the patent owner for appeal