Case Explained: COMMUNICATIONS, LLC v. SAMSUNG ELECTRONICS CO., LTD

Court: United States Court of Appeals for the Federal Circuit Filed: 2026-07-30 The Federal Circuit affirmed the Patent Trial and Appeal Board’s final written decision in an inter partes review that claims 1–5, 7–9, 14, and 20 of U.S. Patent No. 10,736,130 are unpatentable because they are anticipated by prior art reference U.S. Patent No. 10,615,925 (“Kwak”). The court applied the substantial evidence standard under the Administrative Procedure Act to review the Board’s factual findings and legal conclusions regarding anticipation under 35 U.S.C. § 102. The court rejected G+ Communications’ argument that the Board violated due process by relying on an argument Samsung raised at oral hearing, finding that G+ had adequate notice of the issue because it had previously raised the “comb structure” argument and the relevant “may” language was contained within Kwak itself. Furthermore, the court held that substantial evidence supported the Board’s determination that Kwak discloses all claim limitations, including the mapping of predefined sequences to subcarriers. The court reasoned that a prior art reference anticipates a claim even if it does so only in some modes of operation, and credited expert testimony confirming that Kwak’s figures did not necessarily depict a comb structure. As a result, the Board’s decision finding the challenged claims unpatentable stands, and Samsung prevails in the inter partes review proceeding. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.