Fresh From the Bench: Latest Federal Circuit Court Cases

CASE OF THE WEEK

M & K Holdings, Inc. v. Samsung Elect. Co., Ltd., Appeal No. 2020-1160 (Fed. Cir. Feb. 1, 2021)

In only its third precedential patent case of 2021, the Federal Circuit addressed two discrete issues. It established further precedent concerning whether references on web pages and as part of meetings of interested artisans qualify as printed publications for purposes of prior art. It also returned to the issue of the proper scope of the PTAB’s authority in deciding inter partes reviews.

The patents at issue involve methods for compressing video files. Samsung filed IPRs alleging a combination of anticipation and obviousness over four papers. The four papers were all generated in connection with the work of a joint task force to establish industry standards for high-efficiency video coding.