Background
Federal Express Corporation owns a patent for a hierarchical sensor network used to monitor packages during shipping. Qualcomm Incorporated petitioned for inter partes review of the patent, arguing that specific claims were unpatentable as obvious over prior art references. The Patent Trial and Appeal Board instituted the review and determined that the challenged claims were unpatentable under Section one thousand and three of Title thirty-five of the United States Code. FedEx appealed the Board’s decision, challenging the claim construction of short range limitations and the Board’s failure to address arguments regarding power management instructions.
The court’s reasoning
The court reviewed the Board’s claim construction de novo and found that the term short range communication path is relative to the longer range communication path required by the claim. The court concluded that wireless local area network technology satisfies the short range limitation when the longer range path is a satellite relay. However, the court held that the Board violated the Administrative Procedure Act by failing to address FedEx’s argument that the power management instruction must alter operations of both the mobile master node and the ID node simultaneously.
The dissent
What it means going forward
This ruling clarifies that relative terms in patent claims must be interpreted based on the relationship between the terms rather than fixed external standards, while reinforcing the requirement that administrative bodies must address all substantive arguments raised by parties.
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