Apple’s IPR Victory in Data Patent Challenge Overturned by CAFC
Written March 20, 2019
The US Court of Appeals for the Federal Circuit on March 8, 2019, overturned Apple Inc.’s IPR victory against PersonalWeb Technologies, LLC, holding that the ‘310 patent was not unpatentable due to obviousness because one of the PTAB’s key underlying fact findings was not supported by substantial evidence. Personal Web Techs., LLC v. Apple, Inc., Fed. Cir., 3/8/19.
The ‘310 patent, owned by PersonalWeb, describes a data processing system that creates a unique identifier for each data item that doesn’t depend on the item’s user-defined name or location, but only on the data content itself. Apple successfully challenged the validity of the ‘310 patent on the grounds that a prior invention, the Woodhill system, inherently discloses the comparison of a data item’s content-based identifier to a large set of values.
However, the Federal Circuit found this finding insufficient to render the ‘310 patent invalid for obviousness, explaining that probabilities or possibilities may not establish inherency.
The ‘310 patent, owned by PersonalWeb, describes a data processing system that creates a unique identifier for each data item that doesn’t depend on the item’s user-defined name or location, but only on the data content itself. Apple successfully challenged the validity of the ‘310 patent on the grounds that a prior invention, the Woodhill system, inherently discloses the comparison of a data item’s content-based identifier to a large set of values.
However, the Federal Circuit found this finding insufficient to render the ‘310 patent invalid for obviousness, explaining that probabilities or possibilities may not establish inherency.