CPC Patent Technologies Pty Ltd. v. Assa Abloy AB, Nos. 2024-1492, 2024-1493 (Fed. Cir. 2025) (nonprecedential); U.S. Patent No. 8,620,039

Key point(s):

• Substantial evidence did not support the Board’s finding that prior art reference Hsu discloses “defining” a memory location for biometric data based on card information
• “Association” of data stored in a database (as in Hsu) does not “define” the memory location at which that data are stored

Canatex Completion Solutions, Inc. v. Wellmatics, LLC, No. 2024-1466 (Fed. Cir. Nov. 12, 2025) (Precedential) (3-0); U.S. Patent No. 10,794,122

Key point(s):

• Judicial correction of a clear clerical error in patent claims is permissible under a demanding standard when the error is evident from the patent’s face and admits only one reasonable correction based on intrinsic evidence
• Corrections of clear clerical error must be minor, obvious to a skilled artisan, and not subject to reasonable debate, distinguishing judicial fixes from broader PTO authority under 35 U.S.C. § 255

Smartrend Manufacturing Group (SMG), Inc. v. Opti-Luxx Inc., Nos. 2024-1616, -1650 (Fed. Cir. Nov. 13, 2025) (precedential) (3-0); U.S. Patent Nos. D932,930, 11,348,491

Key point(s):

• For a design patent claim, broad construction of a term in the description that contradicted the intrinsic evidence constituted reversible error and necessitated a new trial
• For a utility patent claim, narrow construction based on intrinsic evidence supported a finding of literal infringement, while denial of JMOL on doctrine-of-equivalents infringement constituted reversible error when the accused product failed to perform key functions disclosed in the specification

Samsung Electronics Co., Ltd. v. Power2B, Inc., Nos. 2023-2121, 2023-2122 (Fed. Cir. Nov. 14, 2025) (nonprecedential); U.S. Patent Nos. 10,664,070 and 9,946,369

Key point(s):

• A reply argument that is not found in the petition is properly excluded under 37 C.F.R. § 42.23(b)
• The PTAB has the discretion to read ambiguous petition language as appropriate in determining whether an argument has been clearly articulated

Inventist Inc. v. Ninebot Inc. (USA), No. 2024-1010, 2024-1267 (Fed. Cir. Nov. 14, 2025) (nonprecedential); U.S. Patent No. 8,807,250

Key point(s):

• Evidence of noninfringing alternatives need not be commercially available during infringement under Grain Processing Corp. v. American Maize-Products Co., 185 F.3d 1341 (Fed. Cir. 1999)
• Appeal of the denial of a new trial on marking compliance is dismissed for lack of jurisdiction when no amended notice of appeal was filed under Fed. R. App. P. 4(a)(4)(B)(ii)