Centripetal Networks, LLC v. Keysight Technologies, Inc.

Centripetal Networks, LLC v. Keysight Technologies, Inc. The Federal Circuit affirmed the Board's obviousness findings as to claims 1–3, 5–13, and 15–20, holding that substantial evidence supported the Board's claim construction of 'packet flow entry' and its finding that Sourcefire (alone or combined with Macaulay) disclosed the relevant limitations. The court reversed as to claims 4 and 14, holding that the Board's non-obviousness determination lacked substantial evidence support because the Board improperly read a 'continuous updating' requirement into the claims and its subsidiary factual findings regarding Sourcefire's disclosures were internally inconsistent and unsupported by the record. The decision illustrates that PTAB factual findings on obviousness must be internally consistent across related claims—a Board cannot find that prior art discloses a feature sufficient for one claim while simultaneously finding the same feature absent for a dependent claim without a principled distinction, and importing a 'continuous' limitation from a specification example without clear claim support is reversible error. Affirmed in part, reversed in part. Claims 1–3, 5–13, and 15–20 remain unpatentable; claims 4 and 14 are now also unpatentable for obviousness. Claim construction / notice: The Board did not violate APA notice requirements by construing 'packet flow entry' rather than 'packet flow' because Centripetal itself proffered a meaning for 'packet flow entry' in its briefing and was directly questioned on the term at the oral hearing; the Board may adopt a construction neither party proposes without running afoul of the APA. Claim construction / substance: The Federal Circuit affirmed the Board's construction of 'packet flow entry' as an entry reflecting packets sharing a common feature (e.g., a common threat ID), not limited to packets from the same connection between two endpoints, because the '917 Patent's own specification (Figures 5G and 6G) shows a single entry aggregating packets from multiple distinct connections. Obviousness / claims 1–3, 5–13, 15–20: Substantial evidence supported the Board's findings that Sourcefire discloses packet flow analysis data, a device that updates a packet flow entry based on packet log entries, and packet time data; Centripetal's arguments merely invited the court to draw a contrary inference from the same record, which is insufficient to overcome the substantial evidence standard. Obviousness / claims 4 and 14 (cross-appeal): The Board erred on three independent grounds—(1) its finding that Sourcefire lacks an 'existing flow log entry' was internally inconsistent with its claim-1 finding that Sourcefire's refresh updates a flow log entry; (2) it improperly imported a 'continuous updating' requirement into claims 4 and 14 from a non-limiting specification example; and (3) it ignored Keysight's petition evidence (including expert testimony and annotated screenshots) showing Sourcefire discloses modification of a flow log entry to indicate corresponding packet-filtering rules and packet disposition. Reversal standard: The court reversed outright (rather than remanding) on claims 4 and 14 because only one answer was supported by substantial evidence and there was no apparent reason to grant a second record-making opportunity, consistent with Corning v. Fast Felt Corp. § 103 claim construction remand non-precedential § 103 claim construction remand non-precedential § 103 claim construction remand non-precedential