Garmin v. Cuozzo Speed Technologies
Full2012-00001 · US6778074B1
In plain English: The Board reviewed these claims and cancelled all of them.
How to read this page: start with the Case brief above, use (the small numbered links) to open the exact source page they cite, then use Reference material further down for claim-by-claim and ground-by-ground detail.
All challenged claims cancelled
The Board instituted review of three of the patent's twenty challenged claims and cancelled all three as unpatentable, a result the Federal Circuit and the Supreme Court both affirmed on further review.[19][22][29]
Petition filed September 16, 2012·Institution decision January 9, 2013·Final written decision November 13, 2013·Federal Circuit panel affirms February 4, 2015·Federal Circuit denies rehearing en banc July 8, 2015·Supreme Court affirms June 20, 2016
- The challenged patent covers a vehicle speedometer that shows the driver both the current speed and the legal speed limit for that location.[10][11]
- The Board denied institution on seventeen of the twenty challenged claims but instituted review of claims 10, 14, and 17 on two obviousness grounds.[3]
- Applying the broadest-reasonable-interpretation standard, the Board construed integrally attached to require two discrete parts joined together, then found all three instituted claims obvious and denied Cuozzo's bid to amend them.[13][19][20]
- The Federal Circuit affirmed over Judge Newman's dissent, the full court denied rehearing en banc, and the Supreme Court affirmed again, holding the institution decision unreviewable.[22][24][6][8]
Cuozzo remains the leading precedent on the limited judicial review of PTAB institution decisions, even though the broadest-reasonable-interpretation standard it upheld no longer governs inter partes review.[28]
- Petition filedSeptember 16, 2012
Petition · Paper 1 · Petition filed · View paper
- InstitutedJanuary 9, 2013
Institution · Paper 15 · Instituted on claims 10, 14, 17 (2 of 10 grounds) · View paper
- Final written decision issuedNovember 13, 2013
Final Written Decision · Paper 59 · Claims 10, 14, 17 cancelled; MTA denied · View paper
- AffirmedDate unknown
Federal Circuit · Affirmed (In re Cuozzo, 778 F.3d 1271) · View paper
- AffirmedDate unknown
Supreme Court · Affirmed (579 U.S. 261 (2016)) · View paper
- PTAB Invalidates Patent in First Final Written Decision in New Inter Partes Review Proceeding
Goodwin · November 18, 2013
- Cuozzo Speed Technologies, LLC. v. Lee: The Supreme Court Affirms both the Nonappealable Nature of Institution Decisions and use of Broadest Reasonable Construction Standard in IPR Proceedings
Venable · June 20, 2016
- Cuozzo Speed Technologies, LLC v. Lee: Business as Usual and Uncertainty for Post-Grant Proceedings
George Washington Law Review · June 26, 2016
Reference material
Claim-by-claim and ground-by-ground records underlying the brief above.
| Claim | Ground 1: §103 — Aumayer US6633811, Evans US3980041, Wendt US2711153 | Ground 2: §103 — Tegethoff DE19755470A1, Awada US6515596, Evans US3980041, Wendt US2711153 |
|---|---|---|
| 10 | Unpatentable[1] | Unpatentable[2] |
| 14 | Unpatentable[1] | Unpatentable[3] |
| 17 | Unpatentable[1] | Unpatentable[3] |
- [1] Paper 59 at 28-38
- [2] Paper 59 at 39-47
- [3] Paper 59 at 39-47; brief marks pincite "same" as claim 10 under ground B
- Ground 3: §102Not instituted
Aumayer US6633811
Claims 1-2, 6-13, 18-20
Paper 15 at 24-25; sec_102(e); Aumayer alone does not anticipate - Ground 4: §102Not instituted
Tegethoff DE19755470A1
Claims 1-2, 6-7
Paper 15 at 24-25; sec_102(b); Tegethoff alone does not anticipate - Ground 5: §102Not instituted
Tokunaga US5375043
Claims 1
Paper 15 at 24-25; sec_102(b) - Ground 6: §103Not instituted
Aumayer US6633811, Evans US3980041
Claims 3-5, 14-16
Paper 15 at 24-25; adding Evans alone is not enough - Ground 7: §103Not instituted
Tegethoff DE19755470A1, Evans US3980041
Claims 3-5
Paper 15 at 24-25; same gap unfilled - Ground 8: §103Not instituted
Tegethoff DE19755470A1, Awada US6515596
Claims 8-13, 18-20
Paper 15 at 24-25; Awada adds nothing decisive - Ground 9: §103Not instituted
Tegethoff DE19755470A1, Awada US6515596, Evans US3980041
Claims 14-16
Paper 15 at 24-25; still missing the colored-display teaching - Ground 10: §103Not instituted
Tokunaga US5375043, Hamamura JPH07182598
Claims 10, 20
Paper 15 at 24-25;
- US6778074Other
- Paper 1Paper 1 · Petition
- Paper 15Paper 15 · Institution Decision
- Paper 59Paper 59 · Final Written Decision
- 778 F.3d 1271 (panel, 2014-1301)Federal Circuit Opinion
- 793 F.3d 1268 (reh'g en banc denied)Federal Circuit Opinion
- 579 U.S. 261 (15-446)Supreme Court Opinion