“This Court could have decided differently than the Commission did on the issue of fact at hand, but it is not the Court’s jurisdiction to do so.” – CAFC
The U.S. Court of Appeals for the Federal Circuit (CAFC) ruled Friday that the Patent Trial and Appeal Board (PTAB) correctly found that Roku, Inc. failed to prove the challenged claims of Universal Electronics, Inc. . Patent is clear. Judge Stoll formulated the majority opinion, and Judge Newman dissented, citing procedural and substantive problems with the majority’s analysis.
This decision is related to Roku’s US Patent No. 9,716,853, which covers universal remote controls in general. Specifically, the patent describes a “universal control engine (UCE) that facilitates communication between a control device (i.e., remote) and an intended target appliance.” The patent states that universal remote controls were known at the time of their invention, but that “the prevalence of new methods of communication increases the likelihood of ‘confusion, misoperation, or other problems’.” Both by the appliance and the functions performed. The ‘853 patent’s improvement, therefore, was to “ensure a variety of communication methods that would allow a single remote control to provide commands to a variety of target devices, according to the optimal communication method for each target device and command.” function to use”.
Roku challenged claims 1, 3, 5, and 7 of the ‘853 patent via inter partes review (IPR) proceedings, arguing that the claims were obvious in view of the US patent publication. 2012/0249890 (“Chardon”) and other prior art references. The case was filed before both the PTAB and the CAFC that “Chardon stated in each of the challenged claims that “at least a first method of communication and a second method of communication different from the first method of We have decided whether to disclose a list consisting of 2 methods of communication.
In its petition, Roku detailed how Chardon described the process of creating a database of command codes, but the CAFC said, “How a list of command codes is a list of ways to communicate It does not explain the The court said:
In its petition, Roku assumed that Chardon’s command codes were formatted for transmission over various communication methods, so the list of command codes was necessarily a list of communication methods. But Roku didn’t clarify this assumption or explain how the documentary evidence backed it up. ”
Roku also did not offer claim construction, noting that the claim language should receive the plain and ordinary meaning determined by the ‘853 specification.
The committee ultimately decided that Roku had failed to demonstrate that a skilled craftsman understood that command codes and communication methods were one and the same.
In its discussion, the CAFC acknowledged that “both sides of this dispute of fact can be seen,” but substantial evidence supported the Board’s approach and judgment. It appears that the factual dispute at hand has been hotly contested and rigorously decided,” the court said, but the PTAB’s holding was “flowing from the ‘853 patent specification itself and from Universal’s expert testimony.” The evidence supported it because there was a decision. The majority further stated that its role as an appellate court was not to make fact-finding or review evidence, and therefore that “this court differs from what the Commission did on the issue of fact at hand.” “We could have made a decision, but that’s not our jurisdiction.” court to do so. ”
Judge Newman’s dissenting opinion challenged the court’s reasoning, refused to reconsider the legal issues of claim construction and obviousness, and instead supported the court’s decision to reconsider only the Board’s findings of fact. did not agree. In response to Newman’s dissenting opinion, the majority said, “Roku clearly raises only a matter of fact on appeal: whether Chardon teaches a particular claim element.” As such, the court viewed the issue of appeal as “the underlying Graham factor of obviousness, rather than as an issue of final conclusion of obviousness,” he notes in the CAFC footnote.
But Newman said this “misunderstands” her objection:
“I don’t claim”[] Need to apply a de novo review to this [factual] …I affirm that de novo review should be applied to the appeals question, the legal question of obviousness. “It is the jurisdiction and duty of the judiciary to make clear what the law is. Those who apply a rule to a particular case must necessarily explain and interpret the rule. yeah. Marbury v. Madison, 5 US 137, 177 (1803). This basis for appeal review applies regardless of whether the facts are contested. ”
In Newman’s analysis of the claims at issue, she argues that “because the claimed process and the prior art are substantially the same and serve the same purpose and use, they are obvious from Chardon’s point of view. It would be,’ he said.
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Author: New Africa
