Federal Circuit Clarifies Mandate Rule Scope in PTAB Remand Proceedings

Short summary

The Federal Circuit affirmed a PTAB obviousness ruling, holding that the mandate rule only bars reconsideration of issues actually decided on appeal. On remand, the Board addressed a 'compressing' claim limitation it had not reached in its original decision, which the Court found permissible because that issue was never before it in the first appeal. The Court also found substantial evidence supported the obviousness determination based on a secondary reference describing MPEG standards.

• •Federal Circuit clarified mandate rule applies only to issues actually decided on appeal
• •PTAB could address 'compressing' limitation on remand since it was not reached in original decision
• •Court affirmed obviousness finding with secondary reference supplying MPEG compression evidence

Generated with AI, which can make mistakes.