Case Explained: INTELLECTUAL PIXELS LIMITED v. SONY INTERACTIVE ENTERTAINMENT LLC

Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-07-10

The Federal Circuit affirmed the Patent Trial and Appeal Board’s (PTAB) second final written decision holding claims 1–12 of U.S. Patent No. 10,681,109 unpatentable as obvious under 35 U.S.C. § 103. The court rejected the appellant’s argument that the PTAB violated the mandate rule from a prior remand by addressing the “compressing” limitation of the claims on remand. The court applied de novo review to the scope of its prior mandate, concluding that the mandate was limited strictly to the “generating” limitation, which had been vacated and remanded because substantial evidence did not support the Board’s initial finding that the prior art failed to disclose generating new images. Because the PTAB’s first decision did not reach the merits of the “compressing” limitation as an independent basis for its judgment, that issue remained open on remand and was not foreclosed by the mandate rule. Furthermore, the court found the Board’s second decision supported by substantial evidence, noting that the combination of the Wiltshire reference (disclosing server-based image generation) and the Saha reference (disclosing MPEG compression standards) provided sufficient proof that a person of ordinary skill in the art would have found the claimed invention obvious. As a result, the patent claims remain invalid, and the appellant is ordered to pay costs to the appellee.

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