THE CHAMBERLAIN GROUP, INC. v. ONE WORLD TECHNOLOGIES, INC.
- Dec 17 2019 |
- Category: CAFC Updates
One World Technologies petitioned for IPR of certain claims of U.S. Patent No. 7,196,611 relating to garage door and gate operator systems that include an interactive learn mode. One World’s petition asserted anticipation under 35 U.S.C. § 102(b) by U.S. Patent No. 4,638,433 (Schindler), and obviousness under 35 U.S.C. § 103(a) over the combination of Schindler and an owner’s manual for an industrial duty door operator (LiftMaster). The Board instituted review on all challenged claims on both asserted grounds. The Chamberlain Group appeals the final written decision of the Patent Trial and Appeal Board that the challenged claims are anticipated. The CAFC concludes that the Board erred in finding Chamberlain waived its “responsive to” argument because although the PTO guidelines provide that no new evidence or arguments may be presented at the oral argument, Chamberlain’s arguments at the oral hearing were responsive to One World’s reply and tracked the arguments in its response and did not introduce new evidence at the oral hearing; it merely pointed to different portions of the claim language to clarify its claim construction position. The CAFC finds that the Board’s anticipation findings are supported by substantial evidence, and affirms.