Back to Blog
CAFC-PTOSeptember 2, 2026·24-2240, 24-2241·Affirmed.

Netlist, Inc. v. Micron Technology, Inc.

Patent Trial and Appeal Board

Holding

The Federal Circuit affirmed the Board’s obviousness determinations for all challenged claims. Substantial evidence supported the Board’s motivation-to-combine and reasonable-expectation findings, and the Board adequately explained its reasoning under the APA.

Why It Matters

The decision reinforces that the Board need not address every undisputed limitation in detail when its path is reasonably discernible and supported by the record.

Full Summary

Netlist, Inc. v. Micron Technology, Inc. The Federal Circuit affirmed the Board’s obviousness determinations for all challenged claims. Substantial evidence supported the Board’s motivation-to-combine and reasonable-expectation findings, and the Board adequately explained its reasoning under the APA. The decision reinforces that the Board need not address every undisputed limitation in detail when its path is reasonably discernible and supported by the record. Affirmed. For representative claim 1, substantial evidence supported combining Kim’s TSV-based stacked memory with Rajan’s shared data bus for multiple dies, including evidence that a skilled artisan would look to Rajan when adding more memory chips to Kim’s stack. The court rejected Netlist’s teaching-away and “data collision” arguments, noting that the Board relied on record evidence that Rajan and known industry practices addressed timing and collision concerns. For dependent claim 7, the court agreed that the claim was not limited to different-length TSVs or a nonzero starting load difference; considering load can include a zero load difference. For dependent claim 15, substantial evidence supported the Board’s finding that Wyman taught separate drivers capable of providing different amounts of signal drive. The court rejected Netlist’s APA challenge, holding that the Board’s explanations were adequate, including for limitations Netlist did not separately dispute. § 103 claim construction non-precedential § 103 claim construction non-precedential § 103 claim construction non-precedential

Key Points

  • For representative claim 1, substantial evidence supported combining Kim’s TSV-based stacked memory with Rajan’s shared data bus for multiple dies, including evidence that a skilled artisan would look to Rajan when adding more memory chips to Kim’s stack.
  • The court rejected Netlist’s teaching-away and “data collision” arguments, noting that the Board relied on record evidence that Rajan and known industry practices addressed timing and collision concerns.
  • For dependent claim 7, the court agreed that the claim was not limited to different-length TSVs or a nonzero starting load difference; considering load can include a zero load difference.
  • For dependent claim 15, substantial evidence supported the Board’s finding that Wyman taught separate drivers capable of providing different amounts of signal drive.
  • The court rejected Netlist’s APA challenge, holding that the Board’s explanations were adequate, including for limitations Netlist did not separately dispute.
§ 103claim constructionnon-precedential

More on this topic