In re Satius Holding, Inc.
Patent Trial and Appeal Board
Holding
The Federal Circuit dismissed the appeal as moot because, in a companion appeal decided the same day, it concluded that claim 1 of the ’385 patent is invalid. The court did not reach the merits of the PTAB’s obviousness rejection.
Why It Matters
A parallel Federal Circuit invalidity ruling on the same claim can eliminate any live controversy over a PTAB reexamination rejection of that claim.
Full Summary
Key Points
- The appeal arose from an ex parte reexamination of the ’385 patent.
- The PTAB rejected claim 1 on obviousness grounds and denied Satius’s rehearing request.
- The Federal Circuit relied on its same-day companion decision in Satius Holding, LLC v. Samsung Electronics Co., No. 2025-1446, concluding claim 1 is invalid.
- Because the challenged claim was invalidated in the companion case, the court dismissed this PTO appeal as moot rather than addressing the § 103 merits.
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