Ford Motor Company v. AutoConnect Holdings LLC
Patent Trial and Appeal Board
Holding
The Director denied institution of IPR2026-00171 (and companion cases -00172 and -00173) under 35 U.S.C. § 314(a) because Ford Motor Company maintained inconsistent claim construction positions between its IPR petitions and the parallel district court litigation without adequate justification. Specifically, Ford argued indefiniteness for multiple claim terms in district court while applying plain-and-ordinary-meaning in the petitions, and its conditional stipulation to withdraw those indefiniteness arguments only if IPR was instituted was deemed insufficient to cure the inconsistency under the precedential Revvo decision.
Why It Matters
This decision reinforces that a conditional stipulation to abandon inconsistent district court claim construction positions only upon IPR institution is categorically inadequate under § 314(a) — practitioners must either reconcile conflicting constructions in the petition itself or offer an unconditional stipulation. The Director is applying Revvo broadly and consistently, signaling that petitioners with pending indefiniteness contentions in parallel litigation face a high bar to avoid discretionary denial.
- Written description, enablement and indefiniteness (§ 112) →
- Claim construction →
- PTAB discretionary denial →
- PTAB Director Review →
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