October 3, 2025

Federal Circuit Summary for Week Ending October 3, 2025

Rideshare Displays, Inc. V. Lyft, Inc., Nos. 2023-2033, 2023-2034, 2023-2035, 2023-2036, 2023-2037, 2023-2038, 2023-2039 (Sep. 29, 2025) (nonprecedential); Patent Nos. 9,892,637; 10,169,987; 10,395,525; 10,599,199; 10,748,417

Key point(s):

  • A claimed action “in response to” a condition or event need not be construed as excluding an intermediate step.
  • In a § 101 analysis, a claim representing an improvement to a computer user’s experience does not necessarily comport to an improvement in the way the computer functions.

Focus Products Group Int’l, LLC v. Kartri Sales Co., Inc., No. 2023-1446, 2023-1450, 2023-2148, 2023-2149 (Sep. 30, 2025) (precedential) (3-0); Patent Nos. 6,494,248; 7,296,609; 8,235,088; Trademark Nos. 2,355,554; 2,381,995; 4,127,2834; 5,296,144

Key point(s):

  • Claim scope can be disavowed by a species election without traverse and tacitly acquiescing to an Examiner’s cancellation of withdrawn claims at allowance.

Snap Inc. v. You Map, Inc., No. 2024-1120 (Oct. 1, 2025) (nonprecedential); Patent No. 10,616,727

Key point(s):

  • The mere substitution of one known element for another does not necessarily require further evidence of motivation in order to be considered obvious.

Rex Medical LP v. Intuitive Surgical Inc., Nos. 2024-1072, 2024-1125 (Oct. 2, 2025) (precedential) (3-0); Patent No. 9,439,650

Key point(s):

  • A damages expert’s failure to apportion value across multiple patents can provide sufficient grounds for exclusion of the expert’s testimony.
  • A party’s failure to satisfy its burden to show how such value can be apportioned can justify denial of a new damages trial.

Stryker Corporation v. OsteoMed LLC, Nos. 2023-1925, 2023-1926, 2023-1928, 2023-1929, 2023-1979, 2023-2010, 2023-2011, 2023-2012 (Oct. 3, 2025) (nonprecedential); Patent Nos. 8,529,608; 9,351,776; 9,763,716; 10,245,085

Key point(s):

  • Anticipation may be found across disparate disclosures in the same reference where the reference explicitly contemplates combining those disclosures.

US Inventor, Inc. v. USPTO, No. 2024-1396 (Oct. 3, 2025) (precedential) (3-0)

Key point(s):

  • Organizations can assert “associational standing” to sue on behalf of their members if at least one member would have standing to sue on their own right; the interests sought to be protected are germane to the organization’s purposes and neither the claim nor requested relief requires the participation of the individual members.
  • An injury in fact is an invasion of a legally protected interest that is concrete and actual or imminent, not conjectural or hypothetical.

Related Team:

Simon J Harrall

Associate

W. Bruce Patterson

Partner, Practice Head