Slingshot Printing LLC v. Canon U.S.A., Inc.

Slingshot Printing LLC v. Canon U.S.A., Inc. The Federal Circuit affirmed the Board's obviousness determinations. Substantial evidence supported the Board's findings on motivation to combine and the claimed centrally disposed temperature sensor, and Slingshot's teaching-away argument was not preserved as to the asserted combination. The decision reinforces that patent-owner attacks on individual references and unpreserved teaching-away theories are unlikely to disturb a PTAB obviousness ruling based on a supported combination rationale. Affirmed. No costs. The challenged claims covered inkjet printer chips with temperature sensing elements in regions between heater arrays, used to regulate temperature on a per-region basis. The Board found the challenged claims obvious over Benjamin and Giere673, among other references; the Federal Circuit held the Board did not rely on improper hindsight by considering admissions in the patents' background about what was known in the art. Slingshot's argument that Yabe taught away was not raised below against the Benjamin-Giere673 combination; the court also stated the cited Yabe language did not amount to teaching away. The court credited the Board's finding that improved temperature-measurement accuracy for print quality supported motivation to add Giere673's sensors despite Slingshot's cost concerns. Substantial evidence supported the finding that the prior art taught a sensor that was 'substantially centrally disposed,' including expert testimony about the sensor legs' relative placement. § 103 waiver / forfeiture non-precedential § 103 waiver / forfeiture non-precedential § 103 waiver / forfeiture non-precedential