Category: 2025
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IBM v. Zillow Group, Inc.
Anticipation analysis can consider how a skilled artisan would interpret the teachings of a prior art reference in deciding whether a claim limitation is disclosed.
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Coda Development S.R.O. v. Goodyear Tire & Rubber Company
A trade secret description that only lists the functions of a finished product, without disclosing the underlying knowledge needed to develop it, is not sufficiently definite. Likewise, a mere list of components without disclosure of the design or development is insufficient to define a trade secret.
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Adnexus Inc. v. Meta Platforms, Inc.
At the motion‑to‑dismiss stage, a court may construe claim terms when the parties are given proper notice and a chance to argue their positions. Absent that process, the court must apply the construction advanced by the non‑moving party if a term’s meaning is uncertain.
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Seagen Inc. v. Daiichi Sankyo Company, Ltd.
Disclosure of a broad genus does not provide adequate written description for a narrower subgenus or species unless the specification includes reasonably specific support showing possession of that narrower scope.
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In re Gesture Technology Partners, LLC
The estoppel provision of Section 315(e)(1) does not apply to ex parte reexaminations that were brought before a final written decision was issued in a concurrent IPR. The Patent Office has jurisdiction over ex parte reexaminations concerning expired patents.
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EscapeX IP, LLC v. Google LLC
A district court’s finding of exceptionality under Section 285 is reviewed for abuse of discretion, and the degree of deference does not depend on the length of time the case was pending before that court.
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Duke University v. Sandoz Inc.
A patent does not satisfy the written description requirement when the specification presents options that, despite appearing limited, still encompass numerous variations for a claimed compound, unless the specification provides clear “blaze marks” that guide a skilled artisan to the specific compounds or subgenus being claimed.
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Smartrend Manufacturing Group (SMG), Inc. v. Opti-Luxx Inc.
An expert witness who does not qualify as ordinary observer may still testify as to the perspective of an ordinary observer if the expert establishes that they are familiar with the perspective of the ordinary observer.