The U.S. Court of Appeals for the Federal Circuit vacated the PTAB's ruling that invalidated American Science and Engineering's patent claims on inspection systems using pencil-beam radiation sources. The PTAB failed to adequately show that Seppi's scatter detectors could detect radiation when the radiation sources are arranged perpendicularly. AS&E contended that the findings concerning anticipation and obviousness were unsupported by substantial evidence, particularly since the prior art did not address the perpendicular arrangement required in their patent claims.
The CAFC determined that the Board's ruling never expressly found that Seppi's additional detectors detect radiation when the pencil-beam sources are in a perpendicular arrangement.
The appellate court faulted the PTAB for not properly articulating how the asserted prior art's scatter detectors can detect radiation from the claimed pencil-beam configuration.
Claim 1 of the '701 patent discloses an inspection system including first and second pencil-beam radiation sources arranged in a perpendicular configuration.
The Federal Circuit noted that the system taught by Seppi includes additional detectors for detecting radiation, yet it lacked details on the perpendicular arrangement.
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