Fresh From the Bench: Latest Federal Circuit Court Cases

CASE OF THE WEEK

Qualcomm Inc. v. Intel Corp., Appeal Nos. 2020-1589, et al. (Fed. Cir. July 27, 2021)

In the only precedential patent decision issued by the Federal Circuit this week, the Court addressed ‎again the due process and statutory right of parties in IPR proceedings to have notice and an ‎opportunity to be heard on theories that the PTAB may rely on in rendering its decisions. The Court ‎also addressed the requirement that patents drawn to certain processes in computers disclose an ‎algorithm, holding that this requirement did not apply to specialized circuits.‎

Intel filed six IPRs against a Qualcomm patent that relates to techniques for generating power tracking ‎supply voltages in circuits. Intel proposed that a claim limitation in the patent—“a plurality of carrier ‎aggregated transmit signals”—means “signals for transmission on multiple carriers at the same time to ‎increase the bandwidth for a user.” Qualcomm’s proposed construction also included phraseology ‎about increasing bandwidth for the user. The parties never disputed that the signals were required to ‎increase user bandwidth. All briefing by the parties incorporated this agreed requirement. ‎