• Mar 8 2019
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  • Category: CAFC Updates

PersonalWeb Technologies appeals the final written decision of the Patent Trial and Appeal Board in an inter partes review (IPR) proceeding concluding that Apple demonstrated by a preponderance of the evidence that certain claims of U.S. Patent No. 7,802,310 (relating to content-based identifiers in data processing systems created by applying a cryptographic hash function to a data item independent of any user-defined name) are un-patentable as obvious in view of two prior art references – Woodhill and Stefik. In a prior appeal, the CAFC affirmed the Board’s claim construction and vacated and remanded the Board’s obviousness finding for further consideration. The main claim element in dispute in that prior appeal, as in this appeal, was claim 24’s “causing the content-dependent name of the particular data item to be compared to a plurality of values.” On remand, the Board found that Woodhill inherently teaches comparing a Binary Object Identifier to a plurality of Binary Object Identifiers. The CAFC concludes that the Board’s inherency finding lacks substantial evidence, because the proposed, theoretical Binary Object Identifier look-up table that the Board relies on does not necessarily exist in Woodhill, and reverses.

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