The United States Court of Appeals for the Federal Circuit recently issued several opinions in notable patent cases, addressing issues ranging from claim construction to standing and equitable estoppel.
In “ALNYLAM PHARMACEUTICALS, INC. v. MODERNA, INC.”, Judge Taranto affirmed a district court’s ruling on claim construction. The court found that the patentee acted as a lexicographer regarding the term “branched alkyl” within the specification. The definition was considered controlling unless a clear reason to depart from it was presented, which the court did not find in this case.
Judge Moore, in “DOLBY LABORATORIES LICENSING CORPORATION v. UNIFIED PATENTS, LLC”, dismissed an appeal due to lack of standing. The court ruled that the patent owner failed to demonstrate an injury-in-fact required under Article III, despite having statutory rights under the America Invents Act (AIA). The AIA does not grant an informational right concerning real parties in interest in inter partes review proceedings.
In “FRAUNHOFER-GESELLSCHAFT v. SIRIUS XM RADIO INC.”, Judge Lourie reversed a district court’s summary judgment on equitable estoppel. While acknowledging misleading conduct by Fraunhofer-Gesellschaft due to prolonged silence over infringement claims, the court found insufficient evidence that Sirius XM Radio relied on this conduct when migrating to its accused system.
Lastly, “AGILENT TECHNOLOGIES, INC. v. SYNTHEGO CORP.” saw Judge Prost affirming decisions by the Patent Trial and Appeal Board (PTAB). The PTAB’s findings were supported by substantial evidence showing that prior art disclosed claimed functionalities and was enabling for anticipation purposes. Additionally, obviousness determinations were upheld based on reasonable expectations of success inferred by those skilled in the art.
These rulings underscore ongoing complexities in patent litigation related to definitions, standing requirements, and evidentiary standards for establishing reliance and obviousness.