On August 9, the U.S. Court of Appeals for the Federal Circuit issued a nonprecedential ruling in Unification Technologies LLC v. Micron Technologies Inc., affirming the Patent Trial and Appeal Board’s (PTAB) decisions invalidating claims of data management patents owned by Unification Technologies. The Federal Circuit found substantial evidence supporting obviousness based on a single prior art reference, and held that there was no due process issue arising from Kathi Vidal’s actions as lead counsel for petitioner prior to recusing herself from the proceedings following her nomination as Director of the U.S. Patent and Trademark Office.

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