Background
Parus Holdings owns a patent for a voice-operated system for browsing the Internet. Google petitioned for inter partes review of the patent, arguing the claims were obvious based on combinations of prior art references. The Patent Trial and Appeal Board initially denied institution but later granted it after rehearing. The Board ultimately upheld the patent claims, finding Google failed to prove obviousness. Google appealed, challenging the Board’s analysis of the prior art combinations and the claim construction process.
The court’s reasoning
The Court held that the Board committed legal error by considering prior art references in isolation rather than as the combinations asserted in the petition. Additionally, the Board denied Google due process by adopting a claim construction for the term unexpected response without providing adequate notice or opportunity to address it. These errors required vacatur and remand.
We are persuaded that these errors require vacatur and remand.
Google LLC v. Parus Holdings, Inc., 2024-2381 (Fed. Cir. July 13, 2026)
What it means going forward
The Patent Trial and Appeal Board must re-evaluate the obviousness of the patent claims by properly analyzing the prior art references as combined combinations and ensuring parties have notice and opportunity to address claim constructions.