Acting Deputy Chief Administrative Patent Judge Kalyan K. Deshpande denied institution in six inter partes reviews filed by Samsung against GenghisComm covering mobile communications patents, several granted in 2021–2022 and as young as three years. Acting Director Coke Morgan Stewart recused and delegated authority to Deshpande. Deshpande held that shorter patent age alone did not overcome discretionary denial. Deshpande referenced prior discretionary-denial decisions in IPR2025-00780 (patent granted 2017) and IPR2025-00781 (patent granted 2019), emphasizing that parallel district court trial timing risks duplication, added expense, and inconsistent outcomes.
Although the patents challenged in these proceedings have not been in force for as long as those in IPR2025-00780 and IPR2025-00781, this fact alone does not tip the balance against discretionary denial.
[I]t is unlikely that a final written decision in these proceedings will issue before the district court trial occurs, resulting in significant duplication of effort, additional expense for the parties, and a risk of inconsistent
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