Addressing the issue of collateral
estoppel in inter partes review (IPR), the US Court of
Appeals for the Federal Circuit vacated a finding of patentability
by the Patent Trial and Appeal Board (PTAB) in view of the result
of other IPRs and appeals of the challenged patent. MaxLinear,
Inc. v. CF Crespe LLC, Case No. 17-1039 (Fed. Cir., Jan. 25,
2018) (Dyk, J).
CF Crespe owns a patent related to a
broadband television signal receiver for receiving multi-standard
analog television signals, digital television signals and data
channels. MaxLinear challenged the patent in an IPR, arguing that
the claims were invalid as obvious in view of a combination of
prior art references. Ultimately, the PTAB concluded that the
claims were patentable. In its final written decision, the PTAB
relied entirely on its analysis of the independent claims and did
not provide any separate analysis or discussion for the
patentability of the dependent claims. MaxLinear appealed.
