Intellectual Pixels Limited v. Sony Interactive Entertainment LLC

Intellectual Pixels Limited v. Sony Interactive Entertainment LLC The Federal Circuit affirmed, holding that the Board did not violate the prior mandate by addressing the 'compressing' limitation on remand because that issue was not decided in the first Board judgment or the first appeal. The court also held that substantial evidence supported the Board's obviousness determination based on Wiltshire and Saha. The decision is a useful reminder that, after a Federal Circuit remand from the PTAB, issues not actually decided and not necessary to the prior judgment generally remain open for the Board to address. Affirmed; costs awarded to Sony. The challenged claims covered running an interactive software application on a server, generating updated images at the server in response to client user input, and transmitting compressed frames to the client. In the first appeal, the Federal Circuit held that Wiltshire disclosed the 'generating' limitation because it described use with games like Doom, which required real-time generation of updated images. On remand, the Board found the claims obvious, including because Wiltshire disclosed compressed MPEG streams and Saha supplied MPEG compression details for transmitting compressed frames. The Federal Circuit rejected IPL's mandate-rule argument, explaining that the earlier appeal was limited to the 'generating' limitation and did not decide whether the prior art taught the 'compressing' limitation. Substantial evidence supported the Board's reliance on the prior-art disclosures and expert testimony that a skilled artisan would have combined Saha's MPEG compression teachings with Wiltshire's system. § 103 remand precedential § 103 remand precedential § 103 remand