Case Explained: HAFEMAN v. GOOGLE LLC

Court: United States Court of Appeals for the Federal Circuit Filed: 2026-06-05 The Federal Circuit dismissed-in-part and affirmed-in-part the Patent Trial and Appeal Board’s final written decisions holding that U.S. Patents Nos. 10,325,122; 10,789,393; and 9,892,287 were unpatentable for obviousness. The court dismissed the appellant’s challenge regarding the Board’s failure to address a “Sotera stipulation” violation in the parallel district court litigation because such a challenge is barred from judicial review under 35 U.S.C. § 314(d), which prohibits appeals of decisions to institute inter partes review, including matters closely tied to that decision. Regarding the merits, the court affirmed the Board’s claim construction of the “without assistance by a user” limitation, finding that the plain language and specification support the interpretation that the limitation applies only to the initiation or changing of return information, not to the unrecited step of establishing an internet connection. The court also affirmed the Board’s rejection of secondary considerations of non-obviousness, concluding that substantial evidence supported the Board’s findings that the patent owner failed to establish a nexus between evidence of commercial success, praise, and copying and the merits of the claimed invention. Consequently, the final written decisions finding the challenged claims unpatentable remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.