In a landmark ruling, the Federal Circuit affirmed that IPR estoppel under 35 U.S.C. § 315(e)(2) is confined to grounds based solely on patents and printed publications. This decision arose from Ingenico Inc. v. IOENGINE, LLC, where the court upheld a Delaware jury's verdict invalidating IOENGINE's patents despite Ingenico's previous IPR actions. By clarifying the term 'ground' within the estoppel provisions, this ruling resolves significant legal ambiguity, guiding future patent litigation by defining the boundaries of IPR challenges and their implications for district court strategies.
The Federal Circuit ruling in Ingenico v. IOENGINE limits IPR estoppel under 35 U.S.C. § 315(e)(2), applying it only to patents and printed publications.
This decision clarifies the interaction of IPR estoppel with district court litigation strategy, resolving a split among district courts regarding the meaning of 'ground'.
The ruling reinforces statutory boundaries and emphasizes the importance of prior art definitions in determining the scope of IPR reviews.
Ingenico's case serves as a pivotal example of how IPR estoppel operates, showcasing the nuanced relationship between IPR challenges and district court outcomes.
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