The Technology & Information Law Blog

Analysis by Charles Gideon Korrell

  • Adnexus v. Meta: Federal Circuit Rejects Premature Claim Construction at Pleading Stage

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    On December 5, 2025, the Federal Circuit vacated and remanded the dismissal of Adnexus Inc.’s v. Meta Platforms, Inc., holding that the district court prematurely resolved a claim construction dispute under the guise of Rule 12(b)(6) plausibility. The decision is a pointed reminder that, while courts retain flexibility at the pleadings stage, they may not…

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  • Seagen v. Daiichi Sankyo: Federal Circuit Reverses $41M Verdict on Written Description

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    The Federal Circuit’s December 2, 2025 decision in Seagen Inc. v. Daiichi Sankyo Co., No. 23-2424, continues a noticeable and consequential trend: the court’s growing willingness to overturn jury verdicts on written description and enablement grounds as a matter of law. In reversing a $41 million verdict and vacating findings of willful infringement, the panel…

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  • In re Gesture Technology: IPR Estoppel Stops at the PTAB Door, Not Ex Parte Reexamination

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    The Federal Circuit’s December 1, 2025 decision in In re Gesture Technology Partners, LLC, Appeal No. 2025-1075, delivers a clean and consequential message on two recurring pressure points in post-grant practice: the reach of inter partes review (IPR) estoppel under 35 U.S.C. § 315(e)(1), and the Patent Office’s authority to continue adjudicating validity in ex…

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  • Akamai v. MediaPointe: “Best” and “Optimal” Still Demand Objective Boundaries

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    The Federal Circuit’s decision in Akamai Technologies, Inc. v. MediaPointe, Inc., No. 2024-1571 (Fed. Cir. Nov. 25, 2025), reinforces a familiar but still unforgiving rule of patent law: terms of degree such as “best” and “optimal” require objective boundaries anchored in the intrinsic record, not intuition, common sense, or counsel’s assurances that “it all tends…

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  • EscapeX IP v. Google: Frivolous Litigation, Fee Shifting, and the Perils of Doubling Down

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    On November 25, 2025, the Federal Circuit issued a sharp reminder that patent litigation is not a game of attrition and that courts will use fee shifting and sanctions to deter claims that lack a meaningful factual or legal foundation. In EscapeX IP, LLC v. Google LLC, the court affirmed a district court’s award of…

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  • Duke v. Sandoz: Federal Circuit Invalidates Genus Claim for Lack of Written Description

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    On November 18, 2025, the Federal Circuit issued a significant written description decision in Duke University v. Sandoz Inc., reversing a jury verdict and holding claim 30 of U.S. Patent No. 9,579,270 invalid for lack of adequate written description. The opinion is a textbook application of the court’s “blaze marks” jurisprudence and a reminder that…

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  • Smartrend v. Opti-Luxx: When Claim Construction Undoes Patent Infringement Verdicts

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    The Federal Circuit’s decision in Smartrend Manufacturing Group (SMG), Inc. v. Opti-Luxx Inc., Nos. 2024-1616, 2024-1650 (Fed. Cir. Nov. 13, 2025), offers a layered and instructive treatment of two recurring fault lines in patent litigation: claim construction in design patents and the limits of the doctrine of equivalents in utility patents. In a single opinion,…

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  • Canatex Completion Sol’ns v. Wellmatics: When Judicial Claim Correction Saves Patent Claims from Indefiniteness

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    The Federal Circuit’s November 12, 2025 decision in Canatex Completion Solutions, Inc. v. Wellmatics, LLC, No. 2024-1466, provides a clear and disciplined application of the court’s demanding doctrine of judicial claim correction. Reversing a district court’s finding of indefiniteness, the panel held that an obvious drafting error in a patent claim could and should be…

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  • In re Motorola Solutions: Mandamus Cannot Bypass the § 314(d) Bar on IPR Institution Review

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    On November 6, 2025, the U.S. Court of Appeals for the Federal Circuit denied Motorola Solutions, Inc.’s petition for a writ of mandamus seeking to overturn the USPTO’s decision to deinstitute eight inter partes reviews involving Stellar, LLC’s patents. The order in In re Motorola Solutions, Inc., No. 25-134 (Fed. Cir. Nov. 6, 2025), reinforces…

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  • V.O.S. Selections (Learning Resources) v. Trump at the Supreme Court: Verbs, Taxes, and an Exit Ramp

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    The Supreme Court argument in the tariff cases presented the Justices with a familiar but high-stakes question: how far an old statute can be stretched to support a novel assertion of executive power. The Federal Circuit had already answered the core statutory question en banc, holding that the International Emergency Economic Powers Act (IEEPA) does…

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