Apple Inc. v. Smart Mobile Technologies LLC

Apple Inc. v. Smart Mobile Technologies LLC The Federal Circuit affirmed the Board's implicit construction of "multiplexed signals" and its finding that Apple failed to prove the challenged multiplexing claims unpatentable. The court vacated and remanded the Board's obviousness ruling on claim 17 and its dependents because the Board appeared to overlook Smart Mobile's motivation-to-combine response concerning data bottlenecking. The decision underscores that the Board may implicitly construe claims through its analysis, but must still address material motivation-to-combine evidence when finding claims obvious. Affirmed-in-part, vacated-in-part, and remanded; each party bears its own costs. For the claims reciting "multiplexed signals," the court agreed with the Board that the term requires combining multiple signal streams into a pre-transmission composite signal sent over a shared physical pathway, and does not cover mere sequential switching over the same path. Substantial evidence supported the Board's finding that neither Yegoshin nor Bernard disclosed the claimed multiplexed signals under that construction. On Smart Mobile's cross-appeal, claim 17 did not recite "multiplexed signals" but required combining data paths into a single transmission interface to applications on the mobile device. Apple relied on the same Yegoshin-Bernard motivation-to-combine theory for claim 17 that it used for other claims, while Smart Mobile argued the combination would create an undesirable serial-interface bottleneck. Because the Board stated that Smart Mobile and its expert did not address Apple's rationale, despite record evidence to the contrary, the Federal Circuit vacated the obviousness ruling for claim 17 and dependent claims and remanded. § 103 claim construction remand non-precedential § 103 claim construction remand non-precedential § 103 claim construction remand