Federal Circuit Summery for Week Ending July 25, 2025
Largan Precision Co., Ltd. v. Motorola Mobility LLC, No. 24-1468 (July 21, 2025) (nonprecedential); Patent No. 8,514,499
Key point:
- Expert testimony, supported by prior art references, may properly be relied upon as substantial evidence that a person of ordinary skill in the art would be motivated to modify a prior art reference in a particular manner.
IGT v. Zynga Inc., No. 23-2362 (July 22, 2025) (precedential) (3-0); Patent No. 7,168,089
Key point:
- Decisions by the PTO director or the director’s delagatee on issues connected to a decision of whether to institute IPR are unreviewable, even if the PTO’s final written decision summarizes reasoning related to the institution determination.
Sunkist Growers, Inc. v. Intrastate Distributors, Inc., No. 24-1212 (July 22, 2025) (precedential) (3-0);
Key point:
- A similarity of the marks determination that overly relies on certain materials, despite other conflicting materials, is not supported by substantial evidence.
SME Steel Contractors, Inc. v. Seismic Bracing Co., No. 2023-2426 (July 23, 2025) (nonprecedential); Patent No. 7,174,680
Key point:
- Arguments made during prosecution may be relied on by courts to rule out certain claim constructions.
Xerox Corp. v. Snap Inc., No. 23-1893 (July 24, 2025) (nonprecedential); Patent No. 8,489,599
Key point:
- In claim construction, it is proper for a court to decline to import limitations into claims when such limitations are not supported by the record.
Clark v. DocuSign, Inc., No. 24-1301 (July 25, 2025) (nonprecedential); Patent Nos. 8,695,066; 9,391,957; 10,129,214
Key point:
- Claim construction is not necessary if a claim limitation is obvious under either party’s proposed construction.


