Federal Circuit Opinions

Slingshot Printing LLC v. Canon U.S.A., Inc. — Obviousness Ruling Affirmed

The Federal Circuit affirmed the Patent Trial and Appeal Board's final written decision determining that claims 1–5 and 8 of U.S. Patent No. 7,195,341 are unobvious. The Board had found that Canon showed by a preponderance of the evidence that the claims would have been obvious over U.S. Patent No. 6,412,917 (Torgerson) combined with U.S. Patent No. 7,240,997 (Bruce), both from the same field of endeavor as the '341 patent. The court rejected all three of Slingshot's arguments on appeal: that Torgerson does not disclose polysilicon conductor layer connections, that a skilled artisan would not have been motivated to combine the references, and that the Board's analysis of remaining claim limitations was insufficient under the APA.

Nantworks LLC v. Niantic Inc. - Patent Invalidity Affirmed (AR Technology)

The Federal Circuit affirmed the district court's rulings that claims 7, 14, 16, 19, 26, and 31 of U.S. Patent No. 10,664,518 and claims 7, 22, 23, and 25 of U.S. Patent No. 10,403,051 are invalid under 35 U.S.C. § 101 for failing to meet patent eligibility requirements. The court upheld the district court's judgment on the pleadings for the '518 patent claims and summary judgment for the '051 patent claims. For affected parties, this decision eliminates NantWorks' ability to assert these specific patent claims against Niantic's AR games Pokémon Go and Harry Potter: Wizards Unite.

Affirms PTAB Obviousness Rulings in Network-Threat Detection Patent IPR

The Federal Circuit affirmed the PTAB's determination that claims 1–3, 5–13, and 15–20 of U.S. Patent No. 10,193,917 ('the '917 Patent) are not patentable for obviousness, and reversed the PTAB's finding that claims 4 and 14 are patentable. Centripetal Networks appealed the Board's obviousness rulings while Keysight cross-appealed the non-obviousness findings. The court decided the case under 28 U.S.C. § 1295(a)(4)(A). The '917 Patent covers a packet-filtering device for rule-based network-threat detection that applies operators to block or permit network packets and generates log data.