Monthly Archives: March 2015

The Motivation to Combine References: Substantial Evidence and the Obviousness Examination Guidelines

By Stephen C. Hall

A recent opinion by a Federal Circuit panel demonstrates that three years can be a long time in the smartphone industry. MobileMedia Ideas, LLC v. Apple, Inc. targeted Appleā€™s iPhone products and determined, for now at least, the fate of claims in two patents owned by MobileMedia, a non-practicing holding company partially owned by Nokia and Sony. (Fed. Cir. 2014-1060, 2014-1091.) Rulings on two separate patents hinged on whether a skilled artisan would have been motivated smartphoneto combine multiple references.

The determination of obviousness is a legal question based on juror fact findings. In the case at hand, two references in combination taught Continue reading The Motivation to Combine References: Substantial Evidence and the Obviousness Examination Guidelines