Tag: patent law
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Duke v. Sandoz: Federal Circuit Invalidates Genus Claim for Lack of Written Description
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
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
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
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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Merck Serono v. Hopewell Pharma Ventures: When “By Another” Really Means Everyone
The Federal Circuit’s decision in Merck Serono S.A. v. Hopewell Pharma Ventures, Inc., Nos. 2025-1210, -1211 (Fed. Cir. Oct. 30, 2025), delivers a clarifying—and unforgiving—interpretation of what it means for prior art to be “by another” under pre-AIA 35 U.S.C. § 102. The opinion reinforces a long-standing but often underappreciated principle: unless the inventive entity…
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Aortic Innovations v. Edwards Lifesciences: When “Outer Frame” Becomes “Self-Expanding” by Implication
The Federal Circuit’s decision in Aortic Innovations LLC v. Edwards Lifesciences Corp., No. 2024-1145 (Fed. Cir. Oct. 27, 2025), offers a crisp and cautionary reminder of how easily careful prose in a patent specification can harden into claim-limiting lexicography. The case sits at the intersection of claim construction doctrine and drafting practice, and it reinforces…
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Centripetal Networks v. Palo Alto Networks: When Recusal Fails but Secondary Considerations Revive an IPR
On October 22, 2025, the Federal Circuit issued a mixed but consequential decision in Centripetal Networks, LLC v. Palo Alto Networks, Inc., vacating the Patent Trial and Appeal Board’s final written decision and remanding for further proceedings. While the court firmly rejected Centripetal’s sweeping recusal and due process challenges, it nonetheless concluded that the Board…
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Barrette Outdoor Living, Inc. v. Fortress Iron, LP: Prosecution Disclaimer in a Later Continuation Can Narrow an Entire Patent Family
On October 17, 2025, the Federal Circuit issued a detailed and consequential opinion in Barrette Outdoor Living, Inc. v. Fortress Iron, LP, affirming a judgment of non-infringement while also affirming the district court’s rejection of indefiniteness challenges. The case provides a clear reminder that arguments made during prosecution of a later-filed continuation application can narrow…
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IQE PLC v. Newport Fab (Tower Semiconductor): When Patent Filings Trigger Anti-SLAPP Protection
On October 15, 2025, the Federal Circuit issued a precedential opinion in IQE PLC v. Newport Fab, LLC d/b/a Jazz Semiconductor et al., addressing two questions that rarely intersect so directly: (1) whether denials of California anti-SLAPP motions are immediately appealable in cases within the Federal Circuit’s exclusive jurisdiction, and (2) how California’s anti-SLAPP framework…
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Inland Diamond Prods v. Cherry Optical: PTAB Fact Findings Do Not Preclude District Court Validity Challenges
On October 15, 2025, the Federal Circuit vacated and remanded a summary judgment of invalidity in Inland Diamond Products Co. v. Cherry Optical Inc., No. 24-1106, holding that the district court improperly applied issue preclusion based on prior PTAB inter partes review decisions. The ruling reinforces a principle the court has been developing with increasing…