Technical Consumer Products, Inc. v. Lighting Science Group Corp., No. 19-1361 (Fed. Cir. 2020)Annotate this Case
The 968 patent is directed to replacement light-emitting diode (LED) light fixtures and seeks to minimize the need for customization by creating “low profile downlighting for retrofit applications” that accommodates various housing shapes and sizes. TCP petitioned for inter partes review of several claims. The Patent Trial and Appeal Board determined that TCP did not demonstrate by a preponderance of the evidence that claims 1–4, 6, 14, and 15 were anticipated by the “Chou” patent or that claims 3, 4, 7, 8, 11, 12, 16, 17, and 19–23 would have been obvious over Chou alone or in view of other prior art. The Board based its determinations exclusively on its finding that Chou does not disclose a single limitation (H/D limitation) in claims 1 and 20 of the 968 patent, the only independent claims at issue.
The Federal Circuit vacated as to claims 2– 4, 6–8, 12, and 16. The Board’s determination that Chou does not disclose the H/D limitation in claim 1 of the 968 patent is not supported by substantial evidence. The Board’s conclusions regarding the H/D limitation resulted from an erroneous interpretation of the claim language and a misunderstanding of case law. The Board did not address any other arguments regarding the other limitations of claim 1 or of the rest of the challenged claims.