The Federal Circuit reversed a PTAB ruling that deemed Qualcomm's patent claims unpatentable under Section 103, clarifying that applicant admitted prior art (AAPA) should not alone support such findings. Apple challenged Qualcomm's U.S. Patent No. 8,063,674 through inter partes reviews in 2018, initially successfully arguing based on AAPA and various prior patents. However, the Federal Circuit stated the PTAB incorrectly included AAPA as valid prior art for the challenges raised, thus remanding for reconsideration of the other grounds related to patents and publications only.
While reliance on AAPA in combination with prior art patents or printed publications is not dispositive of whether AAPA is included in the basis of a ground...what is dispositive are express statementsâas in Apple's petitions.
The CAFC vacated and remanded the decisions, explaining that the Board's determination that 'prior art consisting of patents or printed publications' includes AAPA was incorrect.
The PTAB originally held: 'Because AAPA is admitted to be prior art and is found in the '674 patent, it can be used to challenge the claims in an inter partes review.'
The U.S. Court of Appeals for the Federal Circuit on Wednesday issued a precedential decision reversing a PTAB ruling that found on remand from the CAFC claims of Qualcomm's patent for integrated circuit devices were unpatentable.
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