SynQor, Inc. v. Vicor Corp., No. 19-1704 (Fed. Cir. 2021)
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SynQor’s 190 patent issued in 2006, as part of an extensive family of patents that disclose technology for DC-DC power converters used in large computer systems and data communication equipment to convert direct electric current from one voltage to another. In 2011, SynQor asserted several patents against Vicor. Vicor petitioned for reexamination of the 190, 702, and 290 patents. The Patent Trial and Appeal Board affirmed that claims of the 702 patent were not unpatentable, finding that “there are incompatibilities in frequency between” prior references Cobos and Steigerwald, and found the challenged claims of the 290 patent not unpatentable based on a combination of Steigerwald, Cobos, and another reference.
The Federal Circuit court affirmed the patentability of the claims of the 290 patent and the finding the 702 patent not unpatentable but did not reach the finding that Steigerwald and Cobos were incompatible. The 190 patent expired in 2018. A year later, the Board issued its decision in the 190 reexamination, rejecting SynQor’s argument that Steigerwald and Cobos had incompatible frequencies.
The Federal Circuit vacated. Common law issue preclusion arising from the 702 and 290 reexaminations collaterally estopped the Board from finding that an artisan would be motivated to combine Steigerwald and Cobos. The Board’s decision on newly presented claims 34–38 became moot with the patent's expiration.
The court issued a subsequent related opinion or order on February 24, 2021.
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