On May 7, 2025, the Patent Trial and Appeal Board (PTAB) affirmed a decision by Acting Director Coke Morgan Stewart, which stated that a district court's invalidity judgment favors the denial of inter partes review (IPR). In the case concerning Hulu, LLC and Pirhana Media Distribution LLC, Stewart highlighted that since the claims were deemed invalid under Section 101, instituting another review was unnecessary. The Fintiv framework, primarily applied to ongoing cases, doesn't apply well here given the prior invalidity ruling, signaling a shift in how patent reviews may proceed.
In this case, 'the efficiency and integrity of the patent system is best served by denying institution,' concluded Stewart.
‘Because the patent claims already stand invalid, it is unnecessary to institute another proceeding to review them for patentability under other grounds,’ Stewart stated.
The Fintiv framework ‘does not fit neatly with the circumstances of this case’ where the district court's prior decision invalidated claims.
Stewart indicated Hulu can raise the issues it planned to in the IPRs before the district court on remand.
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