American National Manufacturing Inc. v. Sleep Number Corp., No. 21-1321 (Fed. Cir. 2022)
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Sleep Number’s patents describe systems and methods that purport to adjust the pressure in an air mattress “in less time and with greater accuracy” than previously known.” In inter partes reviews (IPR), the Patent Trial and Appeal Board found that some, but not all, of the challenged claims were not unpatentable.
The Federal Circuit affirmed, upholding the Board’s decision permitting Sleep Number to present proposed amended claims that both responded to a ground of unpatentability and made other wording changes unrelated to the IPR proceedings. Each proposed substitute claim included at least one responsive narrowing limitation, so Sleep Number was free to include other amendments, including any addressing perceived 35 U.S.C. 101 and 112 issues. American National challenged the proposed claims and the Board was free to determine whether the proposed claims were unpatentable. The Board did not err in determining that the proposed amended claims were enabled, despite an admitted error in the specification; that error and its correction would have been obvious to a person of ordinary skill in the art. The court rejected arguments that the proposed amended claims should have been rejected for allegedly raising an inventorship issue and that the Board inappropriately considered the petitioner’s sales data in its secondary considerations analysis.
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