FOX Factory, Inc. v. SRAM, LLC, No. 18-2024 (Fed. Cir. 2019)
Annotate this CaseSRAM’s patent generally covers an improved bicycle chainring structure that better maintains the chain, obviating the need for extraneous structures. On inter partes review, the Patent Trial and Appeal Board found that the prior art references disclose all the limitations of the SRAM patent’s independent claims and that a skilled artisan would have been motivated to combine the asserted prior art. The Board nevertheless concluded, based on its analysis of secondary considerations, that the challenged claims would not have been obvious. The Federal Circuit vacated. In order to accord substantial weight to secondary considerations in an obviousness analysis, the evidence of secondary considerations must have a nexus to the claims; there must be a legally and factually sufficient connection between the evidence and the patented invention. The Board erred in presuming nexus between the independent claims and secondary considerations evidence pertaining to SRAM’s chainrings. On remand, SRAM will have the opportunity to prove a nexus between the challenged independent claims and the evidence of secondary considerations--that the evidence of secondary considerations is attributable to the claimed combination of wide and narrow teeth with inboard or outboard offset teeth, as opposed to, for example, prior art features in isolation or unclaimed features.
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