Dental Monitoring SAS v. Align Technology, Inc.

Dental Monitoring SAS v. Align Technology, Inc. The Federal Circuit affirmed the Board’s obviousness determinations. Substantial evidence supported the Board’s findings on the combined prior-art teachings, no teaching away, public accessibility of the Maninis reference, and the qualification of Align’s expert. The decision is a practical reminder that Federal Circuit obviousness review remains deferential where the Board ties combined references and expert testimony to the disputed limitations. Affirmed. The patents concern methods for assessing orthodontic aligner fit using patient images, including deep-learning and image-processing approaches to evaluate tooth/aligner separation. The court held that substantial evidence supported the Board’s findings that the asserted combinations taught the disputed limitations, including the “deep learning device,” “service position,” and tooth-outline determination/comparison limitations. Dental Monitoring’s attacks on individual references did not undermine the Board’s combination-based obviousness analysis. The court rejected teaching-away arguments because Salah’s statement that deep learning was “not preferred” did not criticize or discourage its use, and other evidence supported use with the relevant image regions. The court also upheld the Board’s findings that Maninis was publicly accessible before the relevant date and that Align’s expert was qualified despite Dental Monitoring’s argument that he lacked dentistry or orthodontics experience. § 103 § 101 non-precedential § 103 § 101 non-precedential § 103 non-precedential