Fed. Cir. Remands Bicycle Chainring Patent Dispute

The US Court of Appeals for the Federal Circuit on December 18, 2019, vacated and remanded a Patent Trial and Appeal Board (PTAB) decision which invalidated SRAM’s improved bicycle chainring patent for obviousness. Fox Factory, Inc. v. SRAM, LLC, Fed. Cir., No. 2018-2024.

The PTAB found that the cited art disclosed all the limitations of the challenged patent—which claimed a bicycle chainring for engagement with a drivetrain—and that a skilled artisan would have been motivated to combine the cited prior art. The Federal Circuit found that the PTAB erred in its presumption of a nexus between SRAM’s claims and its evidence of secondary considerations for nonobviousness.