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 Apple’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