Iqris Technologies LLC v. Point Blank Enterprises Inc., et al., No. 2023-2062 (March 7, 2025) (Precedential) (3-0); Patent Nos. 7,814,567 and 8,256,020

Key point(s):

• Importing limitations from the specification into the claims does not necessarily flow from all embodiments in the specification including such a limitation.
• Disparaging prior art in the specification is not enough to unequivocally disavow a limitation in the prior art.

Gesture Technology Partners, LLC v. Unified Patents, LLC, No. 2023-1444 (March 4, 2025) (Nonprecedential); Patent No. 7,933,431

Key point:

• A party to an IPR requesting discovery as it relates to potential real parties in interest or parties in privy should not delay in making such a request, ideally raising the issue when such a potential relationship is discovered.

Regeneron Pharmaceuticals, Inc. v. Mylan Pharmaceuticals, Inc., et al., Nos. 2024-2058, 2024-2147 (March 5, 2025) (Nonprecedential); Patent Nos. 11,084,865 and 9,340,594

Key point(s):

• Testing data provided in the specification should be read in light of the rest of the specification.
• Inherency legally requires a limitation to be present necessarily.

Restem, LLC v. Jadi Cell, LLC, No. 2023-2054 (March 4, 2025) (Precedential) (3-0); Patent No. 9,803,176

Key point(s):

• In an anticipation analysis, the court may pull from the specification for fact finding purposes without necessarily importing these limitations onto the claims.
• For product by process claims, prior art which teaches the process does not inherently anticipate the claims; the challenger must show the process inevitably results in the product.

United Services Automobile Association v. PNC Bank N.A., No. 2023-2244 (March 5, 2025) (Nonprecedential); Patent No. 9,224,136

Key point:

• The internal context of a prior art reference and expert testimony may be used to find a negative limitation of the prior art reference.

Odyssey Logistics & Technology Corp. v. Stewart, No. 2023-2077 (Mar. 6, 2025), (precedential) (3-0); Patent App. No. 11/678,021

Key point:

• Failure to raise an Appointments Clause challenge during an initial appeal of a Board decision precludes raising such a challenge in a subsequent appeal of the Board decision.

Immunogen, Inc. v. Stewart, No. 23023-1762 (March 6, 2025) (precedential) (3-0); Patent Application No. 14/509,809

Key point:

• The obviousness inquiry is generally agnostic to the particular motivation of the inventors.

Apple Inc. v. Gesture Technology Partners, LLC, Nos. 2023-1475, -1533 (Mar. 4, 2025) (precedential) (3-0); Patent No. 7,933,431

Key point(s):

• Securing a favorable claim construction is, by itself, not enough to win an IPR challenge if the petition fails to demonstrate how relevant limitations of the claims are met by the prior art
• Arguments about the knowledge that a person of ordinary skill in the art would have should not be inconsistent with express disclosures in a relevant prior art reference.

AliveCor, Inc., v. Apple Inc., No. 2023-1512, -1513, -1514 (March 7, 2025) (precedential) (3-0); U.S. Patent Nos. 9,572,499; 10,595,731; 10,638,941

Key point:

• A proper analysis of a prior art reference involves reading the prior art reference for all that it teaches, including uses beyond its primary purpose.