RadIP Secures Federal Circuit Appellate Win Against Philips Lighting on Behalf of WAC Lighting
April 20, 2018. RadIP secured an appellate win at the Federal Circuit affirming the Patent Trial and Appeal Board’s prior determination that all petitioned claims of Philips’ U.S. Patent No. 6,013,988 were invalid. In its Opinion, the Federal Circuit rejected Philips’ arguments that a skilled artisan would not have been motivated to combine the prior art or have had a reasonable expectation of success in doing so.
The Federal Circuit rejected Philips’ argument that the PTAB relied on a “broad notion of ‘design choice’” but instead “insisted on reviewing the context-specific evidence for the soundness of that rationale in the particular circumstances of this review.” Opinion at 8. The Federal Circuit affirmed the PTAB’s determination that changing the order of the components “was an obvious matter of design choice because the two designs were known in the art, recognized as solutions to the particular problem, and functionally equivalent.” Id. at 9. The Federal Circuit further rejected Philips’ argument that an identification of a specific “affirmative reason” to make this obvious design choice, finding that Philips was “demanding too much,” as the findings were enough for a skilled artisan to choose either of two possible arrangements of familiar circuit elements. Id. at 10-11.
EdisonReport reported on RadIP’s win here.