- Summary of IN RE APPLIED MATERIALS, INC., 2011-1461
- February 21, 2013
- Law Firm: Sughrue Mion PLLC - Washington Office
Federal Circuit, August 29th 2012, 2011-1461
The Court affirmed the decision of the United States Patent and Trademark Office (“PTO”) Board of Patent Appeals and Interferences (“Board”), upholding its rejections under 35 U.S.C. § 103 in separate ex parte reexaminations of the claims of Applied Material (“Applied”)’s Patents.
The Court agreed with the Board that Applied’s claims were obvious based on the prior art disclosure of values overlapping the claimed ranges. The Court further agreed that the claimed groove dimensions were result-effective variables and that Applied failed to provide evidence that these dimensions produced unexpected results.
Applied argued that the prior art did not specify the result of each purported result-effective variable because the prior art did not address the impact of altering each dimension on pad performance. In rejecting this argument, the Court stated that “the prior art need not provide the exact method of optimization for the variable to be result-effective.”