A Patent Trial and Appeal Board (PTAB) ruling that an IBM patent was invalid has been reversed by the US Court of Appeals for the Federal Circuit.
IBM’s US patent (7,631,346) covered a method and system for a user account creation option through a single sign-on process.
It covers technology that gives a user access to multiple applications “without regard to authentication barriers that protect each particular system supporting those applications”.
US Patent and Trademark Office (USPTO) director Andrei Iancu acted on behalf of several private companies in filing two inter partes reviews that argued several claims of the patent were invalid. Some of the private companies who took issue with the patent have settled with IBM and were not parties in this instance.
The Patent Trial and Appeal Board (PTAB) found the claims unpatentable in two instances, due to anticipation from a US patent (7,680,819) owned by Mellmer and for the same reason from a Japanese Publication (Tokkai 2004-302907A) from Sunada.
IBM appealed the PTAB’s ruling, with the US Court of Appeals for the Federal Circuit reversing the Mellmer ruling.
“We have been pointed to no substantial evidence to support the PTAB’s finding that Mellmer discloses the separate ‘single-sign-on’ limitation of all claims at issue.”
However, the court of appeals vacated the decision related to the Sunada ruling, due to it resting on an incorrect claim construction on the federated computing environment limitation of all the claims at issue.
The court remanded the Sunada ruling for further consideration under the correct construction. With relation to the PTAB’s Mellmer decision though, the court of appeals found that it featured the same claim construction error, but said “it does not affect our result”.