In re Zhengxu He

In re Zhengxu He The Federal Circuit held that substantial evidence supported the Board's finding of a motivation to combine Buehler with He '660. The court also rejected the applicant's APA challenge because the Board addressed the substance of his incompatibility and contradiction arguments. The decision reinforces that obviousness does not require bodily incorporation of a secondary reference and that stated automation benefits can support a motivation to combine when tied to the record. Affirmed. The applicant did not dispute that the combined references disclosed all claim elements; the appeal focused on motivation to combine and the Board's handling of applicant arguments. He '660 disclosed automated ingredient delivery benefits, including dependable delivery, reduced space, reduced idle time, and reduced labor cost, which the examiner tied to modifying Buehler's automated kitchen system. The court rejected the argument that He '660's mechanism had to be physically incorporated into Buehler, applying the standard that obviousness asks what the combined teachings would have suggested. The court found no APA violation because the Board responded to the applicant's contradiction and incompatibility arguments with record-based reasoning. The obviousness rejection of claims 1-22 was affirmed. § 103 non-precedential § 103 non-precedential § 103 non-precedential