Assembling the Obviousness Puzzle: Why Piecemeal Prior Art Analysis Falls Short
Patent – Patently-O 2024-12-17
Summary:
by Dennis Crouch
In Palo Alto Networks, Inc. v. Centripetal Networks, LLC, No. 2023-1636 (Fed. Cir. Dec. 16, 2024), the Federal Circuit vacated and remanded a Patent Trial and Appeal Board (PTAB) decision. Judge Stoll's opinion identified two critical flaws in the PTAB's obviousness analysis: (1) Failure to make clear findings on motivation to combine references; and (2) Analysis of prior art references in isolation rather than as a combined whole.
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