On Feb. 4, 2015, in Garmin Int'l v. Cuozzo Speed Tech., LLC, No. 2014-1301 (Fed. Cir. Feb. 4, 2015), the Federal Circuit issued its first decision on an appeal of a final written decision of an inter partes review (IPR). The Federal Circuit held that the "broadest reasonable interpretation" standard for claim construction is the appropriate standard in IPRs and that the decisions of the PTAB to institute an IPR is not reviewable on appeal. Garmin filed a petition requesting the PTAB to institute an IPR, which the PTAB granted on grounds not specifically stated in the petition. At the conclusion of the IPR, the PTAB issued a final written decision finding all challenged claims obvious and denied Cuozzo's motion to amend the claims. Cuozzo appealed to the Federal Circuit on the grant of the petition and PTAB's use of the "broadest reasonable interpretation" standard for claim construction. On appeal, the Federal Circuit in a 2-1 decision affirmed the PTAB's obviousness determination and upheld the Board's use of the broadest reasonable interpretation ("BRI") standard for claim construction. Full text of the opinion is available here.
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