GENERAL ELECTRIC COMPANY v. RAYTHEON TECHNOLOGIES CORP., Appeal No. 2019-1319 (Fed. Cir. December 23, 2020). Before Lourie, Reyna, and Hughes. Appealed from Patent Trial and Appeal Board. (Obviousness)
In an inter partes review (IPR) before the PTAB, GE challenged the claims of a patent owned by Raytheon. The patent is directed to an airplane jet engine, which includes a design for a two-stage gas turbine. GE cited two references as prior art against the claims.
The first reference taught all of the limitations of the asserted claims except for a two-stage gas turbine, and instead taught the use of a one-stage design. The second reference set forth reasons as to why use of a two-stage design would be preferential over that of a one-stage design. Although the PTAB made explicit findings that could be considered as motivation for one skilled in the art to combine the references, the PTAB held that the first reference taught away from using a two-stage design. Thus, the PTAB concluded that one skilled in the art would not have been motivated to combine the references. GE appealed the PTAB’s decision.
Did the PTAB err in holding that the claims of Raytheon’s patent were not obvious over the cited prior art? (continue reading)
Summary by: Donna Mason
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