Addressing patentability, the US Court of Appeals for the
Federal Circuit reversed the Patent Trial and Appeal Board's
(PTAB's) rejection of claims as being anticipated, and vacated
and remanded the obviousness determination, finding that the
PTAB's anticipation determination was not supported by
substantial evidence and that the obviousness determination was
based on insufficiently or inappropriately explained factual
findings. In re: Hodges, Case No. 17-1434 (Fed. Cir., Feb.
12, 2018) (O'Malley, J) (Lourie, J, concurring) (Wallach, J,
concurring in part, dissenting in part).
Hodges filed a patent application directed to a valve assembly
for draining contaminants, condensation and other fluids that
adversely affect the efficiency and function of a pressurized
system. The patent claims a "valve body, wherein said valve
body defines an inlet seat and a first outlet seat downstream of
said inlet seat." In response to a prior art rejection, Hodges
argued that while the